Important Information About Privacy

We are pleased to provide you with this notice of our consumer privacy policies and practices and of your rights. These privacy policies and practices apply to First Citizens Bancorporation, Inc. and to all of the companies within the First Citizens family of companies. In this document, these companies are referred to by such terms as "us," "we," "our affiliates" or "our organization." Customers of the following affiliated companies are receiving this notice:
First Citizens Bank and Trust Company, Inc.
First Citizens Securities Corporation
First Citizens Capital Management, Inc.
The Exchange Bank of South Carolina, Inc.
Merchants and Farmers Bank of Comer, Georgia
FCB/SC Capital Trust I
FCB/SC Capital Trust II
First Citizens Housing Development, LLC
First Citizens CDE, LLC
Congaree 1, LLC
Daniel Island HPR, LLC
Wateree Enterprises, Inc.
Wateree Life Insurance Company
Wateree Agency, Inc.

Our Commitment to Our Customers: We Value Your Trust

Trust is the foundation of our relationship with you. You have selected us to provide financial products and services because you trust us to act with integrity, to administer your accounts accurately, to handle information about you responsibly and to preserve the confidentiality of your financial affairs. We strive every day to earn your trust and confidence.

We recognize and respect your privacy expectations and are committed to protecting your privacy rights. At the outset, we want to assure you that:

• We do not sell our customer mailing lists or other customer information to outside marketing firms.
• We do not disclose medical information except as necessary to process insurance applications and claims or as otherwise required or permitted by law.
• We will continue to protect your privacy rights even after you close your accounts or become an inactive customer.

About This Notice

This notice describes our consumer privacy policies and practices and certain rights you have under federal law. It summarizes what information we collect, how we use it, with whom we share it and what we do to protect it. These policies and practices are intended to protect the confidentiality of your information if you obtained financial products or services from us primarily for personal, family or household purposes. They apply with equal force to both current and former customers. When we use the term "information" in this notice, we mean information that is personal to you and not otherwise publicly available. The policies and practices described in this notice do not apply to or protect information about you that is publicly available, information about business entities, or information about individuals who obtain financial products or services for business, commercial or agricultural purposes.

We Collect and Use Information Responsibly

We limit the information we collect about you to information we need to administer our business and provide you with high quality financial products and services. We use information about you to administer your accounts, process your transactions, serve your financial needs, determine your eligibility for other products and services we offer and provide you with information about products, services and other opportunities that may interest you. The types of information we collect and may share with our banking, insurance and securities affiliates for marketing purposes, unless you tell us not to, include:

• Information about your experiences and transactions with us, with our affiliates or with others. For example, this information may include your account balance, payment history, or credit card usage.
• Information you provide us on applications, personal financial statements or in other oral, written or electronic communications. For example, this information may include your name, address, Social Security Number, employer, assets and income. However, the only information we collect about you through our web sites is information you voluntarily provide.
• Information we receive from consumer reporting agencies (credit bureaus). For example, this information may include your credit history, and other information about your creditworthiness.
• Information we obtain from market research organizations to learn more about you and your financial needs. For example, this information may include demographic information about the neighborhood in which you live.

Note: Medical information obtained as part of an application for insurance is shared only with those within our organization who require access to process the application. Additional standards of confidentiality protect information related to trust and fiduciary services.

We Limit Employee Access to Your Confidential Information

All employees are governed by a Code of Conduct that includes the responsibility to protect the confidentiality of our customers' financial information and other personal information. Employees are bound by this Privacy Policy and are also educated on implementing our organization's security policies and practices. Only employees actively engaged in their assigned duties are permitted access to or use of customer information.

We Share Information Within Our Organization to Serve You Better

Opportunities arise when we can serve you more efficiently and make it easier for you to do business with us by sharing information about you within our organization. For example, if you have an account with one of our affiliates and want to open an account with another, you may not have to furnish application information twice.

As permitted by federal law, we routinely share within our organization information needed to identify and contact you as well as information about your transactions and experiences with us. In addition, unless you tell us not to, we may share other information (which we call "non-experience information") about you within our organization including sharing with our banking, insurance and securities affiliates for marketing purposes, including:

• Information we obtain from your applications, personal financial statements or other forms, such as your income or marital status;
• Information we obtain from a consumer report or a credit bureau, such as your credit history;
• Information we obtain to verify your representations to us, such as open lines of credit you may have with others; and
• Information we obtain from others regarding employment, credit or other relationships you may have with them, such as your employment history.

Companies in our organization who may receive this information are financial service providers, such as our banking, insurance and securities affiliates.

How to Tell Us Not to Share Non-Experience Information

If you ask us not to share non-experience information within our corporate family, you may miss out on financial products and services of interest to you. However, if you prefer that we refrain from sharing non-experience information, you may direct us not to by calling us at 1-888-612-4444. When two or more customers jointly obtain a financial product or service from us, we will treat a request not to share non-experience information made by one of the joint customers as applying to all of the joint customers. We will process your request as quickly as we can.

Your Choice to Limit Marketing (Marketing Opt-Out) and How Not to Share Non-Experience Information with Affiliates for Marketing Purposes

Our First Citizens Bancorporation family of companies: First Citizens Bank and Trust Company, Inc., First Citizens Securities Corporation, First Citizens Capital Management, Inc., The Exchange Bank of South Carolina, Inc., Merchants and Farmers Bank of Comer, Georgia, Wateree Enterprises, Inc., Wateree Life Insurance Company and Wateree Agency, Inc. are providing this notice. Federal law gives you the right to limit some but not all marketing from the companies listed above.

Federal law also requires us to give you this notice to tell you about your choice to limit marketing from First Citizens Bank and Trust Company, Inc., First Citizens Securities Corporation, First Citizens Capital Management, Inc., The Exchange Bank of South Carolina, Inc., Merchants and Farmers Bank of Comer, Georgia, Wateree Enterprises, Inc., Wateree Life Insurance Company and Wateree Agency, Inc. companies.

You may limit First Citizens Bank and Trust Company, Inc., First Citizens Securities Corporation, First Citizens Capital Management, Inc., The Exchange Bank of South Carolina, Inc., Merchants and Farmers Bank of Comer, Georgia, Wateree Enterprises, Inc., Wateree Life Insurance Company and Wateree Agency, Inc. companies, such as our banking, insurance and securities affiliates, from marketing their products or services to you based on your personal information that we receive from any of our other banking, insurance and securities affiliated companies. This information includes, but is not limited to, application information such as your income, assets and liabilities, personal financial statement information, consumer report information such as your credit history, information from others such as open lines of credit, employment history and information from your transactions with us.

Your choice to limit marketing offers from these affiliate companies will apply until you tell us to change your choice. We will treat a request not to share information made by one of the joint customers on an account as applying to all of the joint customers. We will process your request as quickly as we can. To opt-out of sharing non-experience information with our banking, insurance and securities affiliates and to limit marketing offers, call us at 1-888-612-4444.

We Disclose Information to Nonaffiliated Third Parties Only as Permitted by Law

We do not disclose information about you to anyone outside our organization without your consent except as permitted by law. For example:

• We disclose information necessary or appropriate to process your transactions and to maintain and service your accounts with us.
• We disclose information about your experiences with us to credit bureaus in accordance with well-established banking practices and the federal Fair Credit Reporting Act.
• We may disclose information necessary to protect against fraud or loss.
• We may disclose information in response to a subpoena or court order.

We routinely use outside companies to assist us in administering your accounts and in the day-to-day conduct of our business. For example, other companies perform specialized support services for us or on our behalf when they print checks for you, help us process your transactions and service your accounts, and assist us in our marketing efforts.

Sometimes we enter into joint marketing agreements with other financial institutions to offer you products or services we do not currently offer. We may disclose any of the information we collect as described above to companies that perform services (including marketing services) for us or on our behalf and to other financial institutions with which we have joint marketing agreements. However, when we do so:

• We choose our business partners carefully and deal only with reputable companies;
• We limit the information we share to the information the company needs to do the job; and
• The company is required by law or contract to preserve the confidentiality of your information and to restrict its use to the purposes intended. The company cannot use your information for its own purposes.

We also provide your information to others when you give us permission to do so. For example, if you fill out a card we sent you requesting more information about an insurance product offered by a non-affiliated company we told you about, we would forward your request including your name and address to that company. Of course, if you change your mind you can always "opt-out" of that disclosure by calling us at 1-888-612-4444. If you did that, we would not share that information.

Other Privacy Protections

You may have additional privacy rights in the future under the laws of South Carolina or the state in which you reside, and we may be required to send you additional notices or disclosures. We will comply with all applicable state and federal laws that protect the privacy of your information.

A Final Comment

We are confident our consumer privacy policies and practices warrant your trust and confidence. If you have any questions, please contact us at 1-888-612-4444, or you may visit one of our offices. Thank you for doing business with us.

Consumer Tips for Protecting Personal Information

• Never give out your Social Security Number or personal credit information over the telephone unless you initiate the call.
• Tear up or shred receipts, bank statements and unused credit card offers before discarding them.
• Watch your mail. If you are missing a statement, a check or a bill, someone may have changed your address. Call the source to find out why the item is missing. Also, don’t mail sensitive information from your home mail box where it can be taken. Drop it in a post box or at the Post Office instead.
• Review your credit report annually and correct any mistakes.
• Know the reputation of companies you deal with, especially over the Internet.
• Make sure you use secure sites on the Internet. Your browser should display a key or a padlock to indicate secure sites.
• Don’t open suspicious e-mails.
• Protect your Personal Identification Numbers (PINs) and passwords. Change your passwords often, using a combination of letters and numbers.
• Report any suspected fraud immediately.