• All of our consumer customers who have a continuing relationship with us, such as:
• Deposit account
• Loan account
• Safe Deposit Box
• Retail installment contract we hold and service
• Individual Retirement Account where we act as custodian

• 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 available 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, or a company that is owned or controlled by the same company that owns or controls or 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.

• 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

RESOLUTION OF THE BOARD OF DIRECTORS OF SPIRITBANK

On June 17, 2009 the Board of Directors (the “Board”) of SpiritBank (the “Bank”) at its regularly scheduled meeting entered the following resolutions:

Policy on Luxury Expenses

WHEREAS, the Board finds it appropriate to adopt a policy prohibiting excessive or luxury expenditures.

RESOLVED, that the Bank and all employees shall refrain from and be prohibited from making “excessive or luxury” expenditures on:

·         Entertainment or events;

·         Office and facility renovations;

·         Aviation or other transportation services;

·         Other activities or events that are not reasonable expenditures for staff development, reasonable performance incentives, or other similar measures conducted in the normal course of the business operations of the Bank (or its parent company).

FURTHER RESOLVED, that the Bank currently maintains a policy that requires all expenditures in excess of $1,000 to be approved by the CEO or the CFO and that this limitation is sufficient to monitor, control and eliminate the luxury expenditures listed above.

FURTHER RESOLVED, that all expense reports submitted by the CEO and CFO shall also be submitted to the Compensation Committee for review and approval for luxury expenditures set forth above.

I, Brandi Haskins, hereby certify that I am the duly elected Secretary of the Board and that the above and foregoing resolution was entered by the Board of Directors on June 17, 2009.

                                                                        S/ Brandi R. Haskins                                                                                                              Brandi R. Haskins, Secretary

SPIRITBANK EMPLOYEE EXPENSE REIMBURSEMENT POLICY / LUXURY EXPENSE POLICY

EFFECTIVE JANUARY 1, 2009

1.   PURPOSE

Serving our customers and developing new business objectives are some of the key activities in the attainment of our corporate objectives.  This Employee Expense Reimbursement Policy is designed to properly reimburse employees for all appropriate expenses incurred in working toward these objectives.  In addition, the Policy addresses approval, reporting, and record keeping required to conform to regulations and to effectively control costs.

SpiritBank employees should use judgment and consider spending SpiritBank dollars as if they are spending their own.  Lavish expenditures waste the company’s resources and often reflect unfavorably on SpiritBank in the eyes of customers and others.  To the extent possible, employees are expected to minimize reimbursable expenses.

2.   POLICY

This Policy provides employees with a statement of SpiritBank’s policies and procedures related to the expenditure and accounting for company funds used for conducting business.  All employees, including managers approving expense reports, are expected to become acquainted with, and live within, the spirit of this policy.  SpiritBank will reimburse employees for actual, reasonable, and proper expenditures incurred while conducting company business.

The purpose of this Policy is to provide uniform guidelines for all employees’ reimbursable expenses.  Additionally, the Policy provides general guidelines and is not intended to cover every circumstance.  In many instances, it is left to the good judgment of the employees incurring the expense to determine the appropriateness of the expenditure. 

3.   SCOPE

This Employee Expense Reimbursement Policy applies to all employees of SpiritBank.

4.   ORGANIZATIONAL RESPONSIBILITIES and POLICY EXCEPTIONS

Officers, department heads, supervisors, or others designated by management as expense account approvers, are responsible for the approval of expense reports and other required records submitted by employees, including the determination that activities for which the expenses were incurred are permissible expenditures as defined in this Policy. 

Any exceptions to this Policy must have the approval of an Executive Council member.  Unapproved exceptions to this Policy will not be reimbursed.

5.   MONITORING POLICY

SpiritBank relies on employees to follow this policy.  The employee’s supervisor is responsible for monitoring compliance.  By signing an employee’s expense form, the supervisor certifies that the employee is in full compliance with this policy.  Adherence to this policy will be monitored periodically by Management.

6.   COST EFFECTIVENESS

Reimbursable business expense represents a significant cost of doing business for SpiritBank and it is the responsibility of each employee to incur these expenses in the most cost effective manner consistent with the accomplishment of the business mission.  However, no employee is expected to compromise their, or others’, safety for the sake of cost reduction.

7.   EMPLOYEE EXPENSE REIMBURSEMENT FORM REQUIREMENTS

Proper documentation for employee expense reimbursement is accomplished by completing the attached electronic expense reimbursement form, submitting all receipts and obtaining proper approval.

When possible, all small receipts should be affixed to an 8 ½ x 11 sheet of paper to facilitate review and prevent loss of receipt.

Expense Reimbursement Forms must be signed by the employee and their supervisor.

Employee reimbursable expenses exceeding $1,000 and all reimbursable business related expenses must be approved by the CEO or CFO.

Employees must adhere to the following requirements for property completion of the electronic expense reimbursement form and the mileage reimbursement form:

The expense reimbursement form and the mileage reimbursement form must be completed electronically allowing the formulas to calculate automatically.

All business development expenses must be listed individually, with itemized receipts and be accompanied by the customer name, the business purpose for the expense and any other information that management deems necessary.  This information must be entered into the Business Development Detail form included in the attached electronic employee reimbursement form.

Reimbursable mileage expenses must be accompanied by a completed mileage reimbursement form.  The mileage reimbursement form is included in the employee reimbursement form file.  The form must be completed electronically and be itemized.

Mileage to non-bank locations must be accompanied by supporting documentation such as a Mapquest printout in order to substantiate the miles claimed.

If the employee uses a bank purchased automobile, fuel receipts will be required for reimbursement.

8.   CREDIT CARDS

          Generic cards carried in SpiritBank’s name are prohibited.

Individual credit cards carried in SpiritBank’s name will be limited to those held by Senior Management as of December 31, 2009.

Employees using credit cards carried in SpiritBank’s name or using personal credit cards for business related expenses must submit an employee reimbursement form and include itemized receipts.  Credit card statements are not acceptable as receipts.