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.

All employees of CSRA Bank Corp. and its subsidiaries are subject to this Policy and will be held accountable for compliance with this Policy.

If an employee should violate this Policy, the facts and circumstances of the violation will be reported to the Board of Directors. The Board of Directors will then determine what the consequences of the violation will be.

Prompt internal reporting of suspected violations is encouraged. If an employee wishes to report a suspected violation, he or she should report the suspected violation to the President or the Chairman of the Board and report the facts and circumstances of the suspected violation.

Requests for expenditures requiring prior approval should be made to the President or the Chairman of the Board. Such requests will then be submitted to the Board of Directors for action.

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. Requests for renovations other than emergency situations will be submitted to the Board of Directors for approval.

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. Any expenses for excessive entertainment or an excessive event will be submitted to the Board of Directors for approval.

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. Requests for reward conference expenses will be submitted to the Board of Directors for approval.

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. Expenses in addition to those outlined above will be submitted to the Board of Directors for approval.

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. Requests for excessive aviation or other transportation service expenses will be submitted to the Board of Directors for approval.

Spouse Travel:

Expenses of travel for spouses of Company staff to conferences or other functions attended by Company Staff other than reward conferences are generally considered to be appropriate and permitted and will be borne by the Company. Expenses for spouse travel in connection with any items in this Policy requiring approval by the Board of Directors will also be submitted to the Board of Directors for approval.