Community Bankers’ Bank is a provider of correspondent bank technologies, products and services that serve financial institutions. We are responsible to maintain the integrity of information entrusted to us and safeguarding the privacy of our customers and our customers’ customers whose information we may collect. We use any information about our customers and their customers solely to legitimately conduct our business.
Community Bankers’ Bank is precluded from conducting business with the general public. Normally, personal and confidential information is not collected in the course of cash letter and other deposit processing. We generally do not transact nor do we solicit or maintain direct deposit accounts with individuals, partnerships or corporations (other than bank holding companies or other financial institutions, including banks in organization). We are allowed to conduct direct deposit business and direct loan business on a limited basis with officers, directors and principal shareholders of financial institutions and holding companies. We are also allowed to conduct direct deposit business and direct loan business on a limited basis with customers referred to us by other financial institutions. In the course of that business, we may make personal loans or issue credit cards to such officers, directors, principal shareholders, and referrals.
OUR PRIVACY RESPONSIBILITY
Community Bankers’ Bank understands that confidentiality is important to our customers, our shareholders and our client banks, and is essential in our business. Our goal is to offer quality correspondent bank products and services without compromising your privacy. We understand that you expect matters relating to your community bank and financial information relating to your customers to be held in the strictest confidence. We commit to our customers that we will take all reasonable steps to protect the privacy of the information that is shared with us, whether the information is received via telephone, in person, or online at our Web Site or through CBLink.
MAINTENANCE OF ACCURATE INFORMATION
We strive to maintain customer records that are accurate, current and complete in accordance with bank regulations. We have processes to check records for accuracy and make corrections. If you discover that any information we have about you is incorrect, please let us know. We respond to requests to correct inaccurate information as promptly as possible.
USE, COLLECTION AND RETENTION OF INFORMATION
Community Bankers’ Bank, along with most other financials institutions who do business in the United States, is required to provide its customers with a document illustrating the types of customer information it collects and the circumstances under which it may share it. We take this privacy responsibility seriously and have implemented policies and procedures designed to prevent misuse of your information. We collect your information to administer our business and use your information to make products, services and other opportunities available to you. We also use information we collect to identify you, to communicate with you and to help us respond to your requests.
With respect to any agreements that Community Bankers’ Bank may enter into with you and to the extent we receive your “nonpublic personal information” (as such term is defined under Title V of the Gramm-Leach-Bliley Act of 1999, 15 U.S.C. § 6801 et. seq. and the applicable regulations), Community Bankers’ Bank will not disclose or use any such nonpublic personal information other than to carry out the purpose for which such information was disclosed by you to us or as otherwise required by law. Examples of nonpublic personal information include your account balance, credit card use and payment history. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.
Information collected by Community Bankers’ Bank is limited to what is necessary to complete a loan or credit card request and to allow us to provide services that will be of benefit to our respondent banks and their customers. In the loan or credit card application process we collect certain nonpublic personal information about the applicant from the
Information we receive from you on applications or other forms such as name, address, social security number or taxpayer identification number, assets and income(s);
Information about your transactions with us or our affiliates, such as your account balance, payment history, parties to transactions, and credit card usage; and
Information we receive from a consumer reporting agency (credit bureau) such as your creditworthiness and credit history.
This information is only used to better administer our business or to provide our customers with better products, services and opportunities. We recognize that this information is personal to you and at your request we will disclose to you our reasons for collecting it.
EMPLOYEE ACCESS AND USE OF FINANCIAL INFORMATION
Our employees are educated and trained on the importance of confidentiality and privacy of customer information. Our employees are required to keep customer information confidential and never disclose such information to outside third parties. We restrict access to your nonpublic personal information to those of our employees who have a specific business reason to know such information in order to provide our products and services. If our policies and procedures concerning privacy are violated, disciplinary action will be taken.
Community Bankers’ Bank has security procedures in place to prevent unauthorized access to your private information. In addition, we maintain physical, electronic and procedural safeguards in compliance with federal regulations to guard nonpublic personal information. We continually assess new technology for protecting information and upgrade our systems where appropriate.
RESTRICTIONS ON ACCOUNT INFORMATION
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as outlined in this policy or as permitted by law (specifically, Title V of the Gramm-Leach-Bliley Act). We do share information with companies that work with us. These companies are acting on our behalf when they provide these services and are obligated by contract to maintain the information they receive in a confidential manner. They must agree to safeguard personal and confidential information, and they must also abide by applicable laws. We insist that all such third-party relationships adhere to privacy principles at least as strict as those set forth in our Policy. They are never authorized to use the information for any other purposes.
For example, we may provide information:
As necessary to effect, administer or enforce a transaction requested or authorized by the customer, or in connection with servicing or processing a financial product or service requested by the customer.
For required information risk control or for resolving customer disputes or inquiries.
To consumer reporting agencies as permitted under the Fair Credit Reporting Act, or from a consumer report reported by a consumer reporting agency.
To comply with federal, state, or local laws, and other applicable legal requirements.
To comply with a properly authorized civil, criminal, or regulatory investigation, or subpoena or summons by federal, state or local authorities.
DO NOT CALL POLICY
Community Bankers’ Bank respects the wishes of those customers and prospective customers who do not want to receive telephone solicitation calls from the Bank in their homes. It is the policy of the Bank not to make a telephone solicitation call to:
any person who has requested that the Bank not make such calls to the person’s residence; or any person who has put his or her telephone number on a national or state Do Not Call registry, except as otherwise permitted by law.
A “telephone solicitation call” means any call that is made for the purpose of encouraging the purchase of products and services from the Bank.
The Bank maintains a list containing the telephone numbers and names (if provided) of those persons who have told the Bank that they do not want to receive telephone solicitation calls from the Bank. Anyone may be placed on the Bank’s Do Not Call list by:
sending a written request to the Bank at:
Community Bankers’ Bank
P.O. Box 268
Midlothian, Virginia 23113-0268
e-mailing the Bank at: moc.enilnobbc@ofni; or
calling the Bank at: 804-794-5885, extension 0.
The request must provide the 10-digit residential telephone number that is not to be called and the person’s name, if desired.
Once a request has been made, the Bank will add the telephone number and name (if provided) to the Bank’s Do Not Call list within thirty (30) days. The Bank will maintain the telephone number and name (if provided) on the Bank’s Do Not Call list for five (5) years, unless a request is made by the person to have the number removed. If a person’s telephone number changes, another request must be submitted to have the new number added to the Bank’s Do Not Call list.
The Bank intends to comply with all federal and state Do Not Call laws. Any questions concerning the Bank’s Do Not Call Policy may be directed to the Bank’s Operations Department.
OUR WEB SITE
Our web server maintains a “hit log” to indicate the date and time users have visited the site and what pages they have visited. We recognize and respect the privacy of our customers and other visitors and we use the information only to assess the level of interest in the Web Site. Only summaries of this information are used. Individual users are not tracked.
The only personal information we capture has been specifically submitted to us through the “Contact Us” form. This form requires users to give us contact information (like name, address, e-mail address, and telephone number). This information is used to provide information to those who inquire about our products and services and to handle related business matters. The information is also used to get in touch with customers when necessary.
LINKS TO OTHER WEB SITES
Our Web Site is linked to other sites. Community Bankers’ Bank is not responsible for the security or privacy practices of these sites and has no control over the subject matter, content, information, or graphics of the web sites that have links to our web site. Likewise, Community Bankers’ Bank does not endorse any of the products or services marketed at these sites other than those specifically identified as endorsed products. The portal and news features are being provided by an outside source. Community Bankers’ Bank is not responsible for the content. Please contact us with any concerns or comments.
CONTACTING US BY E-MAIL
If you choose to use any of the e-mail links found on this site, please keep in mind that e-mail is not secure. Unless you have reliable information to the contrary, you should never assume that e-mail you send is confidential or ephemeral.
BOARD APPROVAL OF THIS POLICY STATEMENT