We, the officers and employees of Orange Savings Bank, feel that protecting the confidentiality of our customers' information is one of our most important responsibilities. It is fundamental to the high quality we expect in our customer relationships to protect each person's right to privacy. As we explore new technology, train new employees and introduce new and varied products we give high consideration to your privacy concerns and needs.

Established detailed security procedures in technical areas, training on the crucial role employees play in safeguarding customer information and internal checks on controls are ways we protect our customers' financial information.

INFORMATION COLLECTION

The more information we know about our customers, the better we can understand their financial needs and provide them with the appropriate products and services. We accumulate nonpublic personal information about our customers from a variety of sources. Some information is provided to OSB directly by customers themselves on applications or other forms. Other information is developed by OSB as a function for providing a product or service. We also may receive information from outside sources such as consumer reporting agencies. However, we will limit the collection and use of information on our customers to what is necessary to maintain adequate records, assist us in the development of new products and services and comply with all laws and regulations. This means that we will use the information to help us identify and prevent possible risk or loss to OSB, and we will use information collected to help develop new products and services we feel will be beneficial to our customers.

ACCURACY

OSB strives to maintain complete accuracy when obtaining and storing data about our customers. We use internal controls to ensure the accuracy and thoroughness of the information. If at any time you think your accounts may contain information that is incorrect, please notify us immediately. Prompt action will be taken to make the appropriate corrections.

SHARING CUSTOMER INFORMATION

There are various laws that require financial institutions to provide certain customer information to government agencies. State and Federal laws impose certain mandatory disclosures of customer information by financial institutions. It is the policy of OSB to not disclose customer or former customer information to nonaffiliated third parties except as permitted by law. Disclosure of nonpublic personal information about you to nonaffiliated third parties not otherwise permitted by law will only be made with your written consent.

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

It is commonplace for financial institutions to provide information about a customer's credit history on loan or deposit accounts with consumer reporting agencies (credit bureaus). It is also customary for financial institutions to verify the availability of funds on checks given to merchants by the customer. If at any time you wish to view the information we share with these agencies, you are free to do so. Also, if you feel any information we have shared or may share is in error, please contact our credit department. We will do our best to accurately report your banking relationship.

Information requested by customers via telephone will only be released after the customer adequately identifies themselves by answering specific identifying questions.

EMPLOYEE ACCESS

OSB employees are made aware of our high regard for our customers' right to privacy. Training sessions are mandatory for all employees to continuously enhance their knowledge on ways to protect a customer's confidential information. A Statement of Confidentiality is reviewed and signed by every employee at least annually to acknowledge that they are aware of our strict policy concerning the responsibility of each employee to protect the confidentiality of customer information.

Employees are required to follow our "Code of Conduct" concerning the confidentiality of customer information. Employees who violate these principles will be subject to disciplinary action.

At OSB, access to nonpublic personal information is limited to those employees who need to know that information to provide products or services to you. The information obtained is required to be used only for the business stated and may not be shared among employees.

ONLINE WEB SITE POLICY

Maintaining safeguards to enhance the privacy of our customers is of our utmost concern.

Nonpublic personal information received through e-mail will only be used to communicate with you and to handle your request. It will not be sold or transferred to other parties.

The OSB web site contains additional Terms and Conditions which also affect the privacy of our customers. Please read this information prior to entering any personal identifying information or making account transactions through these means.

TO OUR CUSTOMER

We want you, our customer, to know that OSB understands and values our customers' right to privacy.

You have a right to request a copy of this privacy policy at any time and to ask any questions you may have regarding it. A copy of the policy will be provided to a customer at the time a new account is opened, and annually thereafter. Also, a copy may be obtained upon request at any of our locations or it may be accessed through our web site at orangesavingsbank.com.

If at any time you have questions concerning the information we are obtaining from you, please ask your account representative so that the necessity of the information can be explained. We feel that it is your personal information and you have a right to know why we need it and how it will be protected.

CONSUMER COMPLAINT PROCESS

Orange Savings Bank is chartered under the laws of the State Of Texas and by state law is subject to regulatory oversight by the Texas Department of Savings and Mortgage Lending. Any consumer wishing to file a complaint against Orange Savings Bank should contact the Texas Department of Savings and Mortgage Lending though one of the means indicated below: In Person or by U.S. Mail: 2601 North Lamar Boulevard, Suite 201, Austin, Texas 78705-4294 Telephone Number: (877) 276-5550 Fax Number: (512) 475-1360, E-mail: smlinfo@sml.state.tx.us Website: www.sml.state.tx.us

OSB reserves the right to make changes to this policy when necessary. A copy of the policy indicating any changes will be available for your review. All changes will also be posted immediately to our web site.

This notice is effective December 15, 2004

Website Terms of Use

BEFORE USING THIS WEBSITE PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY.

We require that all visitors to our site adhere to the following terms and conditions. If you do not agree to the terms and conditions below, you should not access this site, or any pages therein.

This website is not directed to children, although we may periodically advertise special accounts that may be appropriate for children. Parents of children interested in any of our online services should contact us at one of our many office locations.

Website Content and Links to Other Websites

Orange Savings Bank maintains this website to provide you with information about our products and services. For your convenience, we may also provide links to our related companies and/or various third parties that may be of interest to you The links are provided solely to assist you in locating other useful information on the Internet. When you click on the links to third party sites, you will leave our website and will be redirected to another site.

Orange Savings Bank does not control linked sites. The content on these sites may periodically change without notice. We make no representation or warranty regarding the accuracy of the information contained in linked sites. We suggest that you always verify the information obtained from linked sites before acting upon this information.

We are not an agent for linked third parties nor do we endorse or guarantee their products and services. The products and services offered by external third parties are not products of Orange Savings Bank and are not insured by any governmental agency such as the FDIC.

Also, please be aware that the security and privacy policies on linked sites may be different from our policies, so please read third party privacy and security policies closely.

If you have any questions or concerns about the products and services offered on linked sites, please contact the third party directly.

Investment Products

We may provide links to Investment or Securities companies, which offer products such as stocks, bonds, mutual funds, and annuities. Investment products may be offered directly by Orange Savings Bank, an affiliated company of Orange Savings Bank, or an unaffiliated third party. Please note that investment products available through this site:

• Are NOT financial institution deposits.
• Are NOT insured by any governmental agency such as the FDIC.
• Are NOT obligations of or guaranteed by Orange Savings Bank.
• Involve investment risks, including the possible loss of some or the entire principal amount invested.

Insurance Products

We may also provide links to purchase insurance products. Orange Savings Bank, its affiliated companies, and/or other unaffiliated third parties may offer these products. Please note that insurance and annuity products available through this site:

• Are NOT deposits, obligations of, or guaranteed by Orange Savings Bank or any of its affiliates.
• Are NOT insured by Orange Savings Bank, the NCUA, the FDIC, or any other agency of the United States.
• Certain insurance products, such as annuities, may have investment risk, including the possible loss of value.
• The purchase of an insurance product is not a condition to any loan, product or service offered by Orange Savings Bank, its affiliates, or nonaffiliated third party.
• Insurance products may not be available in all states.

Privacy

Any communication or material that you transmit to us via this site or through electronic mail will be considered confidential and may be used only by Orange Savings Bank for the purposes described in our privacy notice. All information submitted to our website shall be considered and shall remain the property of Orange Savings Bank; this information will only be used internally for the purpose intended or as allowed by law. If you need to communicate personal or confidential information, please do not use the email feature on this website, it may not be a secure email service. If you need to send us an email with personal or confidential information, you should use the secure mail feature within our Internet Banking Service.

Merchants and other third parties on our website may collect personal information when you visit their websites or when you purchase their products. You should review the privacy policies of these third parties prior to the use of their websites and the purchase of their products and services.

Use of Information and Materials

Any and all information, materials, product offerings, services, terms, and conditions are subject to change without notice.

Any dated information on this site is "As Of" its date only. We will use every reasonable effort to include accurate and up to date information on the site, but we make no warranties or representations as to the accuracy of the information. You may contact Orange Savings Bank to verify the accuracy of information.

Not all products and services are available in all geographic areas. We reserve the right to determine your eligibility for any product or service.

Trademark Notices

"FundsXpress" and "FundsXpress and Design" (the "logo") are registered service marks of FundsXpress Financial Network, Inc. The FundsXpress logo consists of two elements: the red "swirl" and the name, FundXpress Financial Network. FundsXpress Financial Network is a service mark of FundsXpress Financial Network, Inc.

All other registered and unregistered trademarks in this document are the sole property of their respective owners.

Copyright Notices

Orange Savings Bank owns copyright in the pages, screens, text, sound recordings, and images appearing at this site unless otherwise indicated.

Limitation of Liability

Because of the possibility of human, mechanical, and computer-related errors as well as other factors, Orange Savings Bank is not responsible for any errors in or omissions from the information contained in or accessed through this website. All such information is provided "AS IS" to the user without express or implied warranties of any kind including the warranties of merchantability, non-infringement of intellectual property or fitness for any particular purpose.

Orange Savings Bank is not responsible for any electronic virus or viruses that you may encounter. We encourage our customers to routinely scan their computers and diskettes using a reliable virus detection product to detect and remove any viruses.

Orange Savings Bank will not be liable for any delay, difficulty in use, inaccuracy of information, malicious code, or other defects on this site, or for the incompatibility between this website and the files in your browser or other site accessing program. Nor will Orange Savings Bank be liable for any other problems you experience due to causes beyond our control.

Hyperlinks to other Internet resources are at your own risk. The content, accuracy, opinions expressed, and other links provided by these resources are not investigated, monitored, or endorsed by Orange Savings Bank or FundsXpress.

No license to you is implied in these disclaimers, except as may be otherwise expressly provided by written agreement between you and Orange Savings Bank. Orange Savings Bank will under no circumstances be liable to you and/or any third party for any lost profits or lost opportunity, or any indirect, special, consequential, incidental or punitive damages whatsoever, arising in connection with this site or use thereof or inability to use by any party, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus, line or system failure, even if financial institution has been advised of the possibility of such damages.

Governing Law

This agreement shall be governed by and construed in accordance with federal statutes and the laws of the state Texas in which Orange Savings Bank has its headquarters.

OVERDRAFT PRIVILEGE POLICY©

(A Discretionary Overdraft Service)

It is the policy of Orange Savings Bank (“we, us, or our”) to comply with applicable laws, rules and regulations, and to conduct business in accordance with strict safety and soundness standards. A non-sufficient funds (overdraft/negative balance) may result from: A) The payment of checks, electronic funds transfers, or other withdrawal requests you initiate; B) Payments authorized by you; C) The return, unpaid, of items deposited by you; D) Charging your account for our applicable service charges and fees; E) The deposit of items to your account which, according to our Funds Availability Policy, are treated as not yet “available” or “finally paid”. We are not obligated to pay any item initiated for payment against your account if your account does not contain sufficient collected funds. Rather than automatically returning, unpaid, all non-sufficient funds items that you may have, if your “eligible account type” has been open for at least thirty (30) days and thereafter you maintain your account in good standing, which includes at least: (A) Continuing to make deposits consistent with your past practices, and bringing your account to a positive balance (not overdrawn) once every thirty (30) days and (B) You are not in default on any loan obligation to us, (C) We reserve the right to require you to pay your outstanding overdraft (negative) balance, including our fees, immediately or on demand., and (D) Your account is not the subject of any legal or administrative order or levy, such as bankruptcy or a tax lien, we will consider, without obligation on our part, approving your reasonable overdrafts up to your assigned Overdraft Privilege Limit, including our fees.

This discretionary service will generally be limited to a $500 overdraft (negative) balance for eligible Free Checking accounts, $750 overdraft (negative) balance for eligible personal checking account types and $1,000 overdraft (negative) balance for eligible Relationship Checking accounts and a $1,000 for overdraft (negative) balance eligible business/commercial checking accounts types. Our normal fees and charges including, without limitation, our non-sufficient funds (NSF) or overdraft (OD) fees; currently $27.00 per non-sufficient funds or overdraft item, (as set forth in our fee schedules) will be charged for each transaction initiated for payment from your checking account that does not have sufficient collected funds.  Typically, we will charge our normal NSF/OD fee whether we approve an overdraft item for payment or return it unpaid. 

Our NSF/OD fees will be included in and count against your assigned Overdraft Privilege Limit. Whether your overdrafts will be paid or not is at our sole discretion and we reserve the right not to pay. For example, we typically do not pay overdrafts if your account is not in good standing as described above, or if you have too many overdrafts. We may refuse to pay an overdraft for you at any time, even though your account is in good standing and even though we may have previously paid overdrafts for you. You will be notified by mail of any non-sufficient funds items paid or returned that you may have; however, we have no obligation to notify you before we pay or return any item. The amount of any overdrafts including our fees that you owe us shall be due and payable immediately. If there is an overdraft paid by us on an account with more than one (1) owner on the signature card, each owner, and agent if applicable, drawing/presenting the item creating the overdraft, shall be jointly and severally liable for such overdrafts including our fees.

·         Optional Overdraft Protection Services: We offer additional overdraft protection services that you may apply for.  These include overdraft protection from an established line of credit account and/or funds transfer from a designated asset account. If you apply and are approved for these optional services, you may save money on the total fees you pay us for overdraft protection services.

·         Ineligible Accounts and Limitations:  Available only for eligible checking accounts that are maintained in good standing as defined above. Savings Type Accounts, Money Market Accounts, Public Fund/Charitable Organization Accounts, Certain Trust Accounts and Minor Accounts (not of legal age) are not eligible for this service. We may, in our sole option and discretion, limit the number of your accounts eligible for Overdraft Privilege to one account per household and/or one account per taxpayer identification number.

·         Eligible Account Types: The account types that are eligible for Overdraft Privilege are: Free Checking; Personal Checking; Relationship Checking; Business Checking.

·         Transactions That May Cause or Create Overdrafts Using Your Overdraft Privilege Limit: NSF transactions initiated for payment against your checking account may be paid by us using your assigned Overdraft Privilege Limit, including our fees, Our NSF/OD fee may be imposed for paying, or not paying, overdrafts you create by: Checks; In person (teller) withdrawal; ATM withdrawal; or other electronic means.

·         You May Always Opt-Out: You may choose at any time to not participate in Overdraft Privilege by notifying one of our Service Representatives who will explain what this (“Opt Out”) means, and the potential consequences, for you.

·         If You Need Help: Of course, overdrafts should not be used to pay ordinary or routine expenses and you should not rely on overdrafts as a means to cover these expenses. If at any time you feel you need help with your financial obligations please contact one of our Service Representatives at (800)300-8904 or (409)883-3563.

·         ALWAYS A DISCRETIONARY^* SERVICE: Our Overdraft Privilege Service does not constitute an actual or implied agreement between you and us. Nor does it constitute an actual or implied obligation of or by us. Our Service Overdraft Privilege represents a purely discretionary courtesy or privilege that we may provide to you from time to time and which may be withdrawn or withheld by us at any time without prior notice or reason or cause.