8/11/2019 Ad Approval Form

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ADVERTISING AND MARKETING APPROVAL POLICY

GENERAL POLICY

It is the Banks policy that all forms of marketing and advertising be approved by the compliancedepartment and senior management prior to use.

REQUESTS FOR APPROVAL OF ADVERTISING

Officers may request approval of advertising and marketing by submitting a copy the item (ifapplicable) together with a completedAdvertising Approval Request Form. One copy of the

request form should be submitted to senior management and one copy to the compliance

department. heAdvertising Approval Request Formshould include a complete description of

the advertisement or promotion and how or where it will be used.

he officer submitting a request is responsible for obtaining the necessary approvals from

compliance and senior management on theAdvertising Approval Request Formbefore

proceeding with an advertisement! promotion or marketing effort.

REGULATORY REQUIREMENTS/RESTRICTIONS

"ertain regulatory disclosures are required for almost all bank advertising. #ome forms of

advertising and marketing! such as lotteries are legally restricted. $roper approval must beobtained from the compliance department and senior management before running any promotion.

he compliance department will ensure that all regulatory and disclosure requirements have been

met and will maintain copies of all advertising for review by e%aminers. #enior management willapprove content and cost.

&arketing efforts will be reviewed to ensure that target markets are not selected using aprohibited basis' race! color! religion! national origin! se%! marital status! age! handicap! familial

status! receipt of public assistance income! or because an applicant has in good faith e%ercised

any rights under the "onsumer "redit $rotection ct. In addition! dvertising to all of the Banksassessment area will be included in the overall plan (as applicable to the products being

marketed).

COMMON MEDIUMS USED FOR ADVERTISING AND MARKETING

s defined by various regulations and laws many of the communications the Bank issues to thepublic and its customers are forms of advertising.

he following are common mediums used for advertising and marketing'

. elevision and radio commercials*

+. Billboards* signs! and banners

,. ds in maga-ines! newspapers! phonebooks! and directories*. /irect mail marketing and form letters*

8/11/2019 Ad Approval Form

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ADVERTISING AND MARKETING APPROVAL POLICY

0. 1lyers! handouts and pamphlets*

2. "lothing items! hats! buttons! pens*

3. Information on the Banks website*4. 5ists of names used for marketing purposes*

6. #pecial offers to waive fees or specially structure accounts*

7. 5otteries! drawings! and contests*. #ponsoring fund raisers in e%change for free advertising*

+. 5inks to other companies websites*

,. llowing other companies to advertise their products or services on bank premises* and. dvertisements for products added to customer statements or receipts.

8hen in doubt as to whether a promotion is considered advertising officers are directed to

contact the compliance department for assistance.

9uestion regarding this policy should be directed to the :ice $resident! "ompliance /epartment.

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