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Panola National Bank Privacy Policy

The directors, management, and staff of Panola National Bank are concerned about and respect the privacy of customers'/consumers' personal financial information. We understand that our customers furnish sensitive information to the bank in the course of daily business, and the bank is committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.

The bank will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. The following privacy policy and disclosure outlines our bank's practice regarding personally identifiable

TYPES OF INFORMATION THE BANK COLLECTS

At Panola National Bank we collect nonpublic, personal information about you from many sources, including the following:.

• Information we receive from you on applications or other forms
• Information about your transactions with us, our affiliates, or others
• Information we receive from a consumer reporting agency

Nonpublic, personal information does not include that which is available from government records, widely distributed media, or government-mandated disclosures.

TYPES OF INFORMATION THE BANK DISCLOSES

The bank does not now, nor does it intend in the future, to disclose any personal information to any nonaffiliated or affiliated third party. By law the bank may disclose certain personally identifiable information without allowing consumers the right to opt out of the sharing agreements. Listed below are circumstances where companies may perform transaction processing for the bank.

• If the transaction, service, or product is requested or authorized by the consumer
• To disclose information necessary to enforce the bank's legal or contractual rights or the rights of any other person who is engaged in the financial transaction
• To disclose information required in the ordinary course of banking business, such as the settlement of claims or benefits, the confirmation of information to the consumer or the consumer's agent, and the billing, processing, or clearing of items in the normal course of business
• To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating the bank, persons who are assessing the bank's compliance with industry standards, and the bank's attorneys, accountants, and auditors
• To the extent permissible under the Right to Financial Privacy Act
• To a consumer reporting agency under the Fair Credit Reporting Act
• To comply with federal, state, or local laws, rules, and other applicable legal requirements

SAFEGUARDING CUSTOMER INFORMATION

Panola National Bank is aware of the risks involved in releasing unauthorized financial information on its customers. Management acknowledges that risks could range from loss of business and confidence to legal litigation involving monetary losses

At Panola National Bank we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The security officer along with the compliance officer are responsible for assuring the appropriate procedures and internal controls are adopted to assure customer financial privacy. Each department will adopt internal controls to assure that customer information is dispensed only as allowed or required by law.

The internal auditor shall include an annual review of privacy related issues in each department and report those findings to the board of directors.

All employees are alerted to the level of confidentiality required in banking relationships during employee meetings and new employee orientation. All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The management of the bank will take disciplinary action against any employee who violates the bank's privacy policy and procedures.

If we change our policy or practice by, for example, adding a category of information that we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure.

RESPONSE PROGRAM

Upon notification of an incident involving misuse or unauthorized access to personal nonpublic information of our customers the management of Panola National Bank will follow the guidelines listed below.

• Assess the nature and scope of an incident and identify what customer information systems and types of customer information have been accessed or misused.
• Notify appropriate law enforcement authorities when required and file a Suspicious Activity Report (SAR) if necessary.
• Notify our primary Federal regulator when required by law.
• Take appropriate steps to contain and control the incident to prevent further unauthorized access to or use of customers information, for example, by monitoring, freezing, or closing affected accounts, while preserving records and other evidence.
• Notify customers who are affected. Customers would be notified in a timely manner either by phone, mail or email.

The board of directors approved this policy on June 12, 2007.

Please e-mail any questions about this policy to Panola National Bank or contact us by phone at (903) 693-2335.