Privacy and Security Policy

In compliance with the Gramm Leach Bliley (GLB) Act, we are providing you a privacy notice outlining our policy and practices.

This notice covers customers who obtain financial products and services for personal, family or household purposes from any of the First Independence companies listed at the end of this notice. This notice:

• Explains how we collect and disclose customer information we obtain in connection with providing you financial products and services.
• Gives you choices. You may tell us your preferences about sharing customer information with other First Independence companies.

Our Commitment To Protecting Your Privacy of Nonpublic Information

Protecting customer information has always been important to us. Access to customer information is limited to those persons who need to know that information. For example, access to customer information is needed to resolve questions or inquiries, for internal security or fraud control, to provide products or services, or to protect or enforce our rights.

We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard customer information.

We Collect Nonpublic Personal Information About You That May Include:

• Information we receive from you on applications and other forms;
• Information about your transactions with our affiliate, (a company we own or control, a company that is owned or controlled by the same company that owns or controls us; ownership does not mean complete ownership) or others; and
• Information we receive from a consumer-reporting agency

Nonpublic Information Disclosed:

We do not disclose nonpublic personal information about our customers or former customers to non-affiliated third parties (outside of First Independence), except as permitted or required by law. We may disclose the information we collect to companies that perform services on our behalf, or we may disclose to financial service providers with whom we have joint marketing agreements such as: bulk mailing companies, direct marketing companies, market research firms.

Other Exceptions to Information Sharing

We may also disclose...

• To consumer reporting agencies.
• In connection with audits or any sale or transfer of your accounts to a First Independence company or division.
• For fraud, security or risk control.
• To help complete a transaction you initiate including information requested to verify the existence or condition of an account.
• When disclosure is required by law, such as pursuant to court order, subpoena, legal process or government agency examination or investigation, annual income statements to IRS, credit bureaus or to protect or enforce our rights.
• To companies that perform services for us in connection with your accounts, such as software companies, collection agencies, check printers, credit card producers.
• As otherwise necessary to service your account or as permitted or required by law.

Customer Information We May Share With Other First Independence Companies

We may disclose all of the customer information we collect (as described above), on customers and former customers, to other First Independence companies. First Independence companies that may receive this information are financial service providers, such as the Bank and First Independence Mortgage, LLC

However, you have the right to ask us not to share certain information about you with other First Independence companies, including:

• Information you give us on applications or other forms, such as your income or marital status.
• Information we obtain from a consumer report, such as your credit score or credit history.
• Information we obtain from others regarding their relationships or transactions with you or to verify what you tell us, such as account balances or employment history.

Fair Credit Reporting Act

Under the Fair Credit Reporting Act, we are permitted to share information about experiences with you or your accounts, with other companies in the First Independence family, such as information we receive from you in applications and information from credit reporting agencies.

You may direct us not to share certain credit information with our affiliates that does not relate solely to our experiences with you or your account, such as information from credit reporting agencies. You may do so by calling us at (313) 256 8400 followed by written correspondence within 10 days to: First Independence Bank of Detroit, 44 Michigan, Detroit, Michigan 48226, Attention Compliance Officer, please provide your name, address, social security number and account number (s).

Joint Accounts

If you are a joint account customer who asks us not to share customer information with other First Independence companies, we will treat your request as applying only to you, unless you tell us otherwise. You are permitted to make this choice on behalf of other joint account customers if the other customers are properly identified. Also one or more joint account customer may make the choice in a single response Please note, however, that if you make this choice on behalf of other joint account customers, it will apply to all accounts of those other customers.

First Independence Companies Covered By This Notice

• First Independence Bank of Detroit (banking)

  Main Office Branch- 44 Michigan, Detroit, Michigan 48226
  Livernois Office- 12200 Livernois, Detroit, Michigan 48204
  7-Mile Office- 7020 W 7 Mile Rd, Detroit, Michigan 48221
  Greektown Office- 400 Monroe, Detroit, Michigan 48226
  Mack/Alter Branch Office - 14740 Mack Detroit, Michigan 48215

• First Independence Mortgage, LLC

• First Independence Mortgage Company (FIMCO)

Our website brings together a combination of industry-approved security technologies to protect data for the bank and for you, our customer. It features a VeriSign-issued Digital ID for the bank's Internet Service Provider hosting our website, Secure Sockets Layer (SSL) protocol for data encryption, and a router and firewall to regulate the inflow and outflow of server traffic.

Secure Data Transfer

Once a server session is established on an https secure page, the user and the server are in a secured environment. Because the server has been certified as a 128-bit secure server by VeriSign, data traveling between the user and the server is encrypted with Secure Sockets Layer (SSL) protocol. With SSL, data that travels between the bank and customer is encrypted and can only be decrypted with the public and private key pair. In short, the bank's server issues a public key to the end user's browser and creates a temporary private key. These two keys are the only combination possible for that session. When the session is complete, the keys expire and the whole process starts over when a new end user makes a server session.

Router and Firewall

Secure forms must filter through a router and firewall before they are permitted to reach the server. A router, a piece of hardware, works in conjunction with the firewall, a piece of software, to block and direct traffic coming to the server. The configuration begins by disallowing ALL traffic and then opens holes only when necessary to process acceptable data requests, such as retrieving web pages or sending customer requests to the bank.

Using the above technologies, your Internet loan application and check reorder transactions are secure.