Electronic Funds Transfer Policy April 2017

THIS COPY OF THE ELECTRONIC FUNDS TRANSFER POLICY REFLECTS WIRES ONLY FOR TRAINING PURPOSES

Section III. Wire Transfers

Blackhawk Bank & Trust routinely performs and receives wire transfers both for internal operations reasons (i.e. receipt of Cash Letter credits) and as a service to our customers.

In the event that a customer wishes to request a wire transfer from Blackhawk Bank & Trust, a number of guidelines should be followed by the personnel involved. When a customer wishes to request a wire transfer, either in person or by phone, they are referred to personnel who can take the necessary instructions from them. This employee enters the information into our WireXchange which automatically assigns a sequence number. Wires may also be submitted online through eCORP Internet Banking with the use of a token. Customers are told that, in the normal course of business, wire transfer requests taken up to 4:00 p.m. will be on that day's business, on days in which both the Main Bank and the Federal Reserve of Chicago are open for normal operations. Wire requests received after 4:00 pm may be sent the same day at the discretion of the President and any other members of senior management that he may authorize; otherwise it will be done the following business day.

Commercially reasonable security procedures

A written wire agreement defines the duties, responsibilities, controls, and liabilities of each party. This agreement should also discuss commercially reasonable security procedures, such as the establishment of a password. Confirmation of a customer’s password will serve as verification and authorization by that customer. If a customer chooses not to enter into a wire transfer agreement with the bank, then they would be subject to all of the other security procedures and controls outlined in the following sections.

Personal

Domestic and Foreign Wires Initiated - In Person In order to request a wire transfer, the individual must present acceptable identification and be an authorized signer on the account. The employee accepting the wire transfer request must confirm the funds are available. The wire transfer request form as well as the wire payment instructions must then be sent to Main Bank for release.

Electronic Funds Transfer2017 - WIRE TRAINING 1 Personal and Business

Domestic and Foreign Wires Initiated - Not In Person, without a current Wire Agreement In order to request a wire transfer, not in person, the customer may phone, fax, or email the payment instructions to the bank. The employee that accepts the wire transfer request must utilize additional security measures to ensure the identity of the customer. First, a return call to the customer using only bank documented contact information must be made. Second, a wire transfer request form will be sent to the customer to sign and have notarized and returned to Blackhawk Bank. Any exception to this policy must be approved and documented by Assistant Vice President or higher. The wire transfer request form must be sent to Main Bank for release.

Domestic and Foreign Wires Initiated - Not In Person, with a current Wire Agreement For customers who process wires more frequently while not present, a formalized Wire Agreement may be requested by the customer or required by the bank. The Wire Agreement allows the customer to establish authorized users, limits, and passwords. Once an agreement is in place, the specified security features must be verified each time a wire transfer is requested, which includes, at minimum, both a callback and password verification feature. Any exception to this policy must be approved and documented by Senior Management. Bank personnel who release wires must verify and further review the information on the wire transfer form before releasing the wire.

Non-customers

A non-customer may request a wire transfer be performed by our bank; however, this must always be done in person and payment made in available funds prior to any wire transfers being completed. Non-customers may not complete a wire transfer request by phone. Non-customers should be screened against the OFAC list or other government list prior to funds being wired out. Notification and documentation will be sent to the BSA department.

OFAC Screening

We will comply with all laws, including the Patriot Act and any other laws that may be aimed at fighting terrorism and/or crime. The bank has a Customer Identification Program in place. (See CIP Policy for more information.) The bank always seeks to have a reasonable belief that it knows the true identity of our customers, including those who are requesting wire transfers. Any existing bank customer should have already been CIP screened, which includes an OFAC screen; thus there is no need to do another OFAC screen. Non-customers who request us to wire funds for them should be screened against the OFAC list or other government list prior to funds being wired out. Wire transfer beneficiaries who are not customers of the bank (and have thus not been through our CIP/OFAC screening) should also be screened against the OFAC list. If our bank examiners conclude that more parties to a wire transfer transaction should be screened against the OFAC list, we will continue to strive to fully comply with the Patriot Act and any other applicable laws.

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Record Keeping

When the wire request form is forwarded to an authorized employee, that employee will sign onto the system with their user code, password, and using any other security items that may be required (such as a token or any other commercially reasonable security features that may be in place); and then proceed to enter the given information onto the wire transfer screens of the WireXchange system. The user verifies the information, reenters the wire amount and beneficiary institution routing number, and releases the wire transfer. Completed wire forms are then sent to the manager of our Moline 70th Street branch for filing. There must be segregation of duties between the person who enters the wire transaction and the person who verifies and releases the wire; one employee should enter a wire and a different employee should verify and release it before it goes out. Ideally, the person who both verifies and releases the wire would not be the person who took the wire request so that we would have further segregation of duties.

The employee will perform the wire transfer in a reasonable amount of time after they have received it from the originating employee. If the cut-off time for performance of the wire has passed or if the request is to be performed at some future date, the receiving employee will hold the wire form and accompanying information until the wire can be sent appropriately. For example, someone could request a wire transfer on a Saturday, but because the Fed is not open on Saturdays, this wire could not be performed until the next business day. In such a case the customer should be notified of the specific day on which the wire transfer will be sent and then an employee of the bank will hold the wire instructions and any accompanying information until that day or enter the transaction with the proper transfer date.

The following recordkeeping requirements are in place for outgoing wire transfers:

Each wire must include a name and address for the originator and a name and address for the beneficiary. If we do not have a name and address for BOTH the originator and the beneficiary, then the wire cannot be sent out until this information is received. In addition, if any other identifying information is submitted, it should be retained with the wire transfer form.

Also, if the transfer originator is Not a Customer, the following additional information will be required and notification and documentation will be sent to the BSA department.

1. Name Address, and phone number. 2. Type of identification reviewed 3. The number of the identification document 4. The Originator's SSN, EIN, Alien ID number, Passport number & country of issuance, or notation that the information was not available. 5. A copy or record of the method of payment An OFAC screening should also be performed.

Electronic Funds Transfer2017 - WIRE TRAINING 3 Interbank transfers will be exempt and NOT subject to the above documentation guidelines.

As regards retention of outgoing wire transfer orders, all records will be retrievable by: (1) Originator's name, (2) Originator's account number, (3) Beneficiary's name, (4) Beneficiary's account number (if applicable), (5) All of the above must also be retrievable by time period. Additionally, transfers made on WireXchange are searchable by sequence number.

All incoming wire transfer payment orders received will be kept as an original, other copy or on electronic media.

At the end of the business day, a bank employee prints the summary statement from the FedLine system to perform the balancing function and the detail summary from WireXchange. The summary statement prints the number and total dollar amount of both incoming and outgoing wire transfers on that day's business. These totals are compared to balance the accounts.

It is the Bank's policy to wire out available funds. Under extraordinary circumstances, though, a member of Senior Management has the authority to approve a "daylight overdraft" on a customer's account. This amount may not exceed that officer’s lending limit for unsecured loans as set forth in the bank’s loan policy. Wire transfers for non- customers should only be made with available funds.

FedLine Considerations Documentation, installation CDs and tokens for the FedLine System should be destroyed when replaced with updated versions, when no longer needed, or when the FedLine relationship is terminated.

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