• All of our consumer customers who have a continuing relationship with us:
  • Deposit account
  • Loan account
  • Safe deposit box
• All IRA accounts for which we act as custodian

We will tell you the sources for nonpublic personal information we collect on our customers. We will tell you what measures we take to secure that information.

We first define some terms.
We, our, and us means First State Bank
Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is avaliable from public sources, such as telephone directories or government records.
An affiliate is a company we own or control, a company that owns or controls us, and a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.
A nonaffiliated third party is a company that is not an affiliate of ours.

We collect 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
• Information about your transactions with nonaffiliated third parties
• Information from a consumer reporting agency

We do not disclose any nonpublic personal information about you to anyone, except as authorized by law.

THE CONFIDENTIALITY, SECURITY AND INTERGRITY OF

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to gurard your nonpublic personal information.

Since we value our customer relationship with you, we will not disclose your nonpublic personal information to nonaffiliated third parties, except as permitted by law.

We do not disclose nonpublic personal information about former customers.

POLICY REGARDING EXCESSIVE OR LUXURY EXPENDITURES

This policy fulfills the requirements under the American Recovery and Reinvestment Act of 2009 (ARRA) enacted February 17, 2009. ARRA requires each recipient of funds under the Capital Purchase Program (CPP) of the Troubled Assets Relief Program (TARP) to have in place a company-wide policy regarding excessive or luxury expenditures, as identified by the Secretary of the Department of the U.S. Treasury.

CSRA Bank Corp. and its wholly-owned subsidiary, First State Bank (hereinafter collectively known as the “Company”), prohibit excessive or luxury expenditures for entertainment and events, office or facility renovations, aviation or other transportation services or other activities or events that are not reasonable expenditures for conferences, staff development, reasonable performance incentives or other similar measure conducted in the normal course of business operations.

Renovations:

Renovations of facilities and office spaces should be relative to current business plans and needs. An exception to this will be allowed if management must deal with an emergency situation, such as an act of nature, and the expenditure is necessary to make the facility operational for customer use.

At no time should renovations be done that would have the appearance of being extraordinary or excessive from a shareholder perspective.

Entertainment:

Entertainment is defined as an activity for which an officer or employee would use Company funds for business development purposes relating to current customers or prospective customers or to further enhance the Company’s marketing efforts. Excessive entertainment or an excessive event is defined as any single occurrence or event where the activity is not designed to enhance the marketing efforts of the Company or support business development efforts of the Company.

Our expectation is that all such expenses paid for by the Company would be for company purposes, and used to generate business for the Company.

Conferences:

We encourage our staff to attend conferences that are appropriate educational opportunities. These conferences should be related to the financial services industry and have a direct correlation to their job. At times it may be appropriate that a spouse would travel to these conferences with Company attendees. Typically these conferences are sponsored by vendors, banking associations, or other industry-related entities.

This policy would exclude reward conferences if the purpose is meant to be a reward, or would have no value of education to the employee or executive.

Holiday Parties:

We feel that holiday parties are part of an employee appreciation process. Holiday parties should be local in geographic nature, and should not cost the Company more than an average day’s payroll per employee, on average.

Board retreats should only be used for educational purposes, and should be considered and looked at in the same view and with discretion as all other expenses. Board education is a vital part of maintaining and keeping a dynamic director base, and this policy should not limit a retreat that is focused on strategic planning or education.

Events and parties focused on customers for the purpose of attracting or retaining their business would not fall under this policy.

Aviation Services:

Transportation for Company staff to conferences, for business development purposes and merger and acquisition research should be conducted in the most cost-appropriate way for the Company. Modes of transportation to be used for the analysis, for example, may consist of vehicle, commercial air service and private air service. A determination of the appropriateness of transportation will factor in cost, efficiency and timeliness of travel. Excessive aviation or other transportation services expenditures are prohibited.