Policies and Notices

We strive to keep our customers up to date on all privacy policies and issues. If you do not see the notice that meets your needs, call or e-mail us at info@southwestbank.com.

Southwest Bank Community Reinvestment Act Notice (CRA)

Under the Federal Community Reinvestment Act (CRA), the Federal Reserve Board (Board) evaluates our record of helping to meet the credit needs of this community consistent with safe and sound operations. The Board also takes this record into account when deciding on certain applications submitted by us.

Your involvement is encouraged.

You are entitled to certain information about our operations and our performance under the CRA, including, for example, information about our branches, such as their location and services provided at them; the public section of our most recent CRA performance evaluation, prepared by the Federal Reserve Bank of Dallas (Reserve Bank); and comments received from the public relating to our performance in helping to meet community credit needs, as well as our responses to those comments. You may review this information today.

At least 30 days before the beginning of each quarter, the Federal Reserve System publishes a list of the banks that are scheduled for CRA examination by the Reserve Bank in that quarter. This list is available from the Officer in Charge of Supervision, Federal Reserve Bank of Dallas, 2200 N. Pearl St., Dallas, Texas 75201. You may send written comments about our performance in helping to meet community credit needs to Shirley Stokes, Vice President, Southwest Bank, P. O. Box 962020, Fort Worth, Texas 76162 and Officer in Charge of Supervision, Federal Reserve Bank of Dallas, 2200 N. Pearl St. Dallas, Texas 75201. Your letter, together with any response by us, will be considered by the Federal Reserve System in evaluating our CRA performance and may be made public.

You may ask to look at any comments received by the Reserve Bank. You may also request from the Reserve Bank an announcement of our applications covered by the CRA filed with the Reserve Bank. We are an affiliate of First Texas BHC, Inc., a bank holding company. You may request from the Officer in Charge of Supervision, Federal Reserve Bank of Dallas, 2200 N. Pearl St., Dallas Texas 75201 an announcement of applications covered by the CRA filed by bank holding companies.

Consumer Complaint Process

Southwest Bank, Fort Worth, Texas, is chartered under the laws of the State of Texas and by state law is subject to regulatory oversight by the Texas Department of Banking. Any consumer wishing to file a complaint against Southwest Bank, Fort Worth, Texas, should contact the Texas Department of Banking.

Southwest Bank also engages in the money transmission and/or currency exchange business as an authorized delegate of American Express Travel Related Services Company, Inc. under Chapter 151 of the Texas Finance Code. If you have a complaint regarding an American Express Travelers Cheque product, first contact the customer service division of American Express at 1-800-221-7282. If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity please direct your complaint to the Texas Department of Banking.

Consumers may file complaints with the Texas Department of Banking by contacting the Department through one of the means indicated below:

Customer Identification Program (CIP)

Important Information about Procedures for Opening a New Account

To help the government fight the funding of terrorism and money-laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person or business that opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you and /or your business. We may also ask to see your driver's license or other identifying documents.

Beware of Internet Scam

Southwest Bank has become aware of a phishing scam on the internet. The scam comes in the form of an email asking customers to update their account information. Please be aware that Southwest Bank will never solicit information from its customers via email or any other form of communication. If you receive any correspondence requesting account information notify a bank employee as soon as possible.

Excessive or Luxury Expenditures Policy

1. Summary and Regulatory Background

It has long been the practice of the First Texas BHC, Inc. (the “Company”) and its wholly owned subsidiary, Southwest Bank (the “Bank”) to control its expenses and to avoid unreasonable or excessive expenditures. On June 15, 2009, the U.S. Department of Treasury (“Treasury”) announced an interim final rule (the “Interim Rule”) that includes standards for executive compensation and corporate governance practices for those entities receiving funding under the Treasury’s Capital Purchase Program (“CPP”), including that CPP recipients adopt an Excessive or Luxury Expenditures Policy. As CPP participants, the Company and the Bank are subject to the requirements of the Interim Rule.

This Excessive or Luxury Expenditures Policy (the “Policy”) is designed to satisfy the requirements of the Interim Rule and will govern expenditures by the Company, the Bank and the officers, directors and employees of each. This policy affirms the Company’s obligation that any excessive or luxury expenditures (as defined below) must comply with the requirements of the Emergency Economic Stabilization Act of 2008 (“EESA”) and the Interim Rule, and sets forth procedures to ensure compliance.

2. Guidelines

The Company prohibits excessive or luxury expenditures on entertainment and events, office or facility renovations, aviation or other transportation services or other activities or events that are not reasonable expenditures for conferences, staff development, reasonable performance incentives or other similar measures conducted in the normal course of business operations of the Company.

The following guidelines shall apply to the following specific types of expenditures:

A. Aviation equipment/services: The Company does not own any jets, airplanes or other aviation equipment, and they will not purchase such equipment.

B. Office and Facility Renovations. Renovations and improvements of Company facilities and office spaces are done to ensure a reasonably comfortable and safe environment for our customers and a reasonably effective and productive work environment for our employees, while balancing the overall expense and benefit to the Company. Situations which create a safety/health hazard for our customers, employees, and/or the public will be remedied as promptly as possible to prevent any accidents or harm to individuals, with expense being a secondary consideration. Office and Facility Renovations are reported to and approved by the Company’s Board of Directors (“Board”).

C. Entertainment and Events. Business development with prospective customers and relationship building with current customers and others is critical to the success of the Company. Accordingly, the Company and its employees are permitted to engage in social activities with prospective and current customers, provided such participation and involvement is reasonable in relation to the value of the business or other relationship to the Company. Attracting and maintaining a high quality and motivated workforce is also essential to the success of the Company. Accordingly, the Company provides activities which recognize employee achievement and performance, promote employee morale, and/or further other legitimate objectives of the Company, subject, however, to being reasonable in cost and scope. While acknowledging the value of entertainment and various customer and employee events, the Company will balance that value with the overall benefit to the Company’s success and ensure money is spent prudently. Entertainment and Events are approved by the employee’s immediate supervisor and reviewed by the CEO.

D. Conferences. The Company encourages continuous learning and development of its employees to maintain a competitive advantage in the market. Attendance by Company personnel at conferences should be primarily for educational purposes and selective other business purposes. Conferences are approved by the employee’s immediate supervisor and reviewed by the CEO.

Determination of whether a proposed expense in any of the above-described categories constitutes an “excessive or luxury expenditure” will be made by the Board, or by Vernon Bryant, CEO, as the Board’s designee.

3. Compliance with Policy and Annual Board Review

Compliance with this Policy will be the primary responsibility of the Company’s CEO. Any questions about whether any expenditure violates this policy should be discussed directly with the CEO, CFO, the Compensation Committee of the Board (the “Compensation Committee”), or directly to the Board. At least annually, sufficient time will be allocated during one of the regular meetings of the Compensation Committee for a general review of this Policy’s requirements in light of the requirements of EESA and the Interim Rule, as the same may be amended from time to time. If it is determined that this policy needs to be revised because of amendments to EESA or to the regulations of Treasury or other relevant regulatory agencies, or because of changes to the policies of Treasury or other regulatory agencies having jurisdiction over the Company, the Board, after consulting with counsel, will make the necessary changes to this Policy.

The Company’s CEO and CFO shall certify that any expenditure requiring pre-approval under this policy was properly obtained.

4. Publication of Policy

Upon approval by the Board, a copy of this Policy will be promptly submitted to Treasury and the Company’s Primary Regulator and will be posted on the Company’s website. If this Policy is amended, a copy of the revised Board-approved Policy will be promptly submitted to Treasury and the Company’s Primary Regulator and the Company’s website will be updated to reflect such amendments.

5. Termination

This Policy will remain outstanding so long as Treasury maintains an investment in the Company pursuant to the CPP.

Unlawful Internet Gambling Notice

Restricted transactions as defined in Federal Reserve Regulation GG are prohibited from being processed through your Southwest Bank account(s). Restricted transactions generally include, but are not limited to, those in which credit, electronic fund transfers, checks or drafts are knowingly accepted by gambling businesses in connection with the participation by others in unlawful Internet gambling.

Equal Housing Lender Member FDIC