Tristar Managing General Agency, Inc.

Customer Information Guidelines

Regulatory Compliance: Tristar’s activities with regard to customer information will be conducted in a manner consistent with, and not in contravention of, statues and regulations applicable to federal savings banks and the published written interpretations of the Office of Thrift Supervision (OTS) with respect thereto; and, other state and federal laws applicable to federally chartered savings banks. Tristar shall maintain the records contemplated by this Agreement in accordance with applicable OTS regulations, including, but not limited to, OTS Regulation 563.170.

Customer Information Privacy: Financial Institution shall not provide any Customer Information (as hereinafter defined) otherwise required to be provided by it to Tristar, and may restrict any use by Tristar of any Customer Information which is provided by Financial Institution to Tristar, if Financial Institution is prohibited from disclosing the same or permitting such use because of any law, regulation, Financial Institution wide privacy policy, public privacy pledge, court order, rule, consent decree, or individual present or former customer request, or if the provision of such information or its intended use would create an additional regulatory compliance burden on Financial Institution.

On or before the effective date of termination of any relative Agreement between Tristar and Financial Institution, Tristar agrees that it shall; (i) immediately destroy and purge from all its systems all information within each Customer Information to the extent that such information in any way identifies an individual as a customer of Financial Institution ("Customer Information"); and, (ii) return or destroy within thirty (30) days all Customer Information that is in tangible form, including any and all full or partial copies, or reproductions thereof in any medium whatsoever. All destruction of Customer Information shall be done in strict accordance with Financial Institution’s then current destruction policy.

All Customer Information are (i) confidential and proprietary and (ii) shall remain the sole property of Financial Institution. Tristar expressly acknowledges and agrees that Tristar has no property right or interest whatsoever in any Customer Information except as expressly provided herein. Tristar shall hold all Customer Information in strict and absolute confidence and shall not provide, trade, give away, barter, lend, send, sell or otherwise disclose (collectively "transfer") any Customer Information and shall not make any copies of a Customer Information of any type whatsoever except as expressly approved in a separate writing by Financial Institution or as necessary to perform under this Agreement. At all times Tristar shall keep in confidence and trust all Customer Information. Tristar further agrees that it shall not transfer any Customer Information to any other organization or individual under any circumstances, and Tristar specifically but not by way of limitation agrees that no affiliates shall be transferred any Customer Information unless agreed to in writing by Financial Institution prior to any such transfer or unless necessary to perform under an agreement executed by and between Tristar and Financial Institution.

Tristar shall have no authority to use Customer Information for any purpose other than its performance under any agreement unless expressly permitted by Financial Institution in a separate writing. Tristar shall comply with any reasonable requests of Financial Institution with respect to security precautions to maintain the security of Customer Information. Tristar agrees to secure and safeguard the Customer Information in strict accordance with the Federal Interagency Guidelines Establishing Standards for Safeguarding Customer Information and the requirements of this Section and Financial Institution’s instructions, as communicated by Financial Institution to Tristar from time to time. Tristar shall only permit access to the Customer Information to those employees, volunteers, agents and/or representatives of Tristar who need such access to perform their duties for Tristar. In view of the confidential nature of the Customer Information, Tristar warrants that Tristar and all its employees, volunteers, agents and/or representatives who work with any Customer Information shall be made aware of the obligations contained in this Section and shall be under strict legal obligation not to copy any Customer Information, transfer any Customer Information or make any other use of any Customer Information other than as specifically approved by this Section.

Tristar agrees that Financial Institution shall be entitled to injunctive relief to prevent violation or further violation by Tristar and/or its employees, volunteers, agents or representatives of this Section IV. Nothing herein shall be construed as prohibiting Financial Institution from pursuing any other remedy on account of such breach or threatened breach.

In the event Tristar receives a request to disclose a Customer Information pursuant to a subpoena, order of court of competent jurisdiction or by judicial or administrative agency or legislative body or committee, Tristar agrees to: (i) immediately notify Financial Institution of the existence, terms and circumstances surrounding such request; (ii) consult with Financial Institution on the advisability of taking legally available steps to resist or narrow such request; and (iii) if disclosure of such Customer Information is required or deemed advisable, exercise its best efforts to obtain an order or other reliable assurance that confidential treatment will be accorded to such portion of the Customer Information to be disclosed which Financial Institution designates.