The First National Bank of Fort Smith

Citizens Bank and Trust Company

National Bank of Sallisaw

First National Bank of Rogers, A Division of FNBFS

We know the safeguarding of your financial information is the basic trust you have placed in us as your Financial Service Provider. Our responsibility to keep the information you provide to us secure and confidential is of the highest priority. We want you to know that our commitment to protect your privacy will extend to all areas of the bank, and you can trust us to keep you informed on the measures we take to protect your privacy. Please be assured that we do not sell our customer information or customer lists to outside marketing firms or agencies. This privacy notice describes what information we collect and how we use it.

Institutions Covered By This Notice:
This notice reflects the privacy policy and information sharing practices for: The First National Bank of Fort Smith, Citizens Bank and Trust Company, National Bank of Sallisaw, and First National Bank of Rogers, A Division of FNBFS.

Some of the terms we use in this notice may be new to you. Therefore, for the purpose of this disclosure, we provide the following definitions for those terms:

Affiliate, means any company that controls, is controlled by, or is under common control with another company.

Non-affiliated Third Party, means any person except:
(1) Our affiliate; or
(2) A person employed jointly by us and any company that is not our affiliate.

Non-public Personal Information, means:
(1) Personally identifiable financial information; and
(2) Any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available.

“You” or “Your” for the purpose of this disclosure and statement mean,
(1) Our consumer customers that maintain account relationships by purchasing or holding financial products or services such as:

• Deposit Accounts
• Loan Accounts
• Safe Deposit Box Services
• Retail Installment Contracts we hold and service
• Insurance Policies issued by or through us
• Financial, Investment, or Economic Advisory Services
• All Managed or Custodial Agency Accounts

(2) All IRA Accounts for which we act as custodian
(3) Former Customers

Information We Collect:
The information we collect is used for a variety of reasons. These reasons may include advising you of our products and services, to facilitate and process transactions in servicing your accounts, and to safeguard and protect your account from unauthorized access. The information we collect includes:

• Information provided by you to support applications for services and other forms we may use;
• Information from your transactions with us, or our affiliates;
• Information from your transactions with nonaffiliated third parties; and
• Information we receive from a consumer reporting agency, such as credit bureau reports and other information relating to your creditworthiness.

Disclosure of Nonpublic Personal Information
We do not disclose nonpublic personal information about you to nonaffiliated third parties except as disclosed in this notice, or as permitted by law . We may disclose this information to service providers and companies that perform services for us such as processing your transactions. We may disclose nonpublic personal information to other financial institutions with which we have joint marketing agreements with respect to financial products and services, provided that the other financial institutions agree to maintain standards of confidentiality similar to our standards and to use the information only for the purposes for which it was disclosed. We may disclose nonpublic personal information about you in order to prevent unauthorized transactions. We may also provide nonpublic information about you to our regulatory agencies, auditors, or other parties as required or allowed by law such as court orders or subpoenas.

Confidentiality and Security of Nonpublic Personal Information
We restrict access to your information to those employees who need to know this information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal requirements to protect this information. We require other companies that we do business with, to maintain these safeguard procedures as well.

Information Sharing Practices Concerning our Affiliates
We may disclose nonpublic personal financial information about you to the following types of affiliates:
Financial service providers, such as:

• Commercial Banks
• Real Estate Appraisal Companies
• Insurance Agencies

The nonpublic personal information we share with our affiliates is limited to your “Transaction and Experience” with us that is maintained in our account records. This information may include:

Names	Account activity	Payment histories
Addresses	Types of accounts	Deposit histories
Account balances	Parties to transactions	Policy coverage
Account numbers	Social Security numbers	Premiums

Federal law allows us to disclose the above listed information with our affiliates. You do not have a right to opt out of the disclosure of this information.

Information Sharing Practices Concerning our Former Customers
We may share nonpublic personal information about our former customers to those entities allowed by law and to our affiliates. However, our policy concerning the sharing of nonpublic personal information about our former customers does not differ from our policy concerning present customers.

Information We Report to Consumer Reporting Agencies
Please notify us if we report any inaccurate information about your account(s) to a consumer reporting agency. Your written notice describing the specific inaccuracy(ies) should be sent to the respective institutions at the following addresses:

• First National Bank of Fort Smith
  P. O. Box 7
  Fort Smith, Arkansas 72902
  (479) 782-2041
  www.fnbfs.com
   
• Citizens Bank & Trust Company
  P. O. Box 469
  Van Buren, Arkansas 72957
  (479) 474-1201
  www.cbankandtrust.com
   
• National Bank of Sallisaw
  P. O. Box 549
  Sallisaw, Oklahoma 74955
  (918) 775-5501
  www.banknbs.com
   
• First National Bank of Rogers, A Division of FNBFS
  P.O. Box 699
  Rogers, Arkansas 72757
  (479) 621-6800
  www.fnbrogers.com

We appreciate the opportunity to be your financial service provider and invite your questions concerning our privacy policy and notice. Should you have questions please contact us at the addresses and telephone numbers listed above.

In addition, if you have a First National Bank of Fort Smith, Citizens Bank and Trust Company,
National Bank of Sallisaw, or First National Bank of Rogers, a Division of The First National Bank
of Fort Smith VISA® Debit Card, we provide the following required notice:

Notice Regarding non-VISA® Pin-less Debit Card Transactions

We allow non-Visa® debit transaction processing. This means you may use your VISA® Debit Card on a PIN-Debit Network (a non-VISA® Network)* without using a PIN to authenticate your transactions.

The non-VISA® debit network for which such transactions are allowed is the Pulse Network.

Examples of the types of actions that you may be required to take to initiate a VISA® transaction on your VISA® Debit Card include signing a receipt or using Verified by VISA® over the Internet.

Non VISA® transactions do not require you to take any action to authorize the transaction.

Please be advised that the terms and conditions of your agreement with us relating to VISA® debit transactions do not apply to non-VISA® debit transactions. For example, the additional limits on liability (sometimes referred to as Visa's zero-liability program) and the streamlined error resolution procedures are not applicable.

If you have any questions about non-VISA® debit transactions, please contact us at the appropriate address.

*VISA® rules generally define Pin-Debit Network as a non-VISA® debit network that typically authenticates transactions by use of a personal identification number (PIN) but that is not generally known for having a card program.

•  First National Bank of Fort Smith
  P.O. Box 7
  Fort Smith, Arkansas 72902
  (479) 782-3041
  www.fnbfs.com
   
• Citizens Bank & Trust Company
  P. O. Box 469
  Van Buren, Arkansas 72957
  (479) 474-1201
  www.cbankandtrust.com
   
• National Bank of Sallisaw
  P. O. Box 549
  Sallisaw, Oklahoma 74955
  (918) 775-5501
  www.banknbs.com
   
• First National Bank of Rogers
  P. O. Box 699
  Rogers, Arkansas 72757
  (479) 621-6800
  www.fnbrogers.com