Disclosures

Disclosures
 

Business Continuity Program
 

Purpose
In accordance with mandated regulations from the Office of Comptroller of Currency (OCC), Citizens Commerce National Bank would like to make you aware of our Business Continuity Program (BCP).  Our program is designed to help ensure that we can continue to do business with little or no disruption that your assets will be secure and accessible and that you will be able to reach us regardless of the unplanned business interruption or scope of the situation.

Recovery Strategies & Plans
Citizens Commerce National Bank’s BCP addresses the recovery of technology systems.  In general, our technology systems are located in alternate sites that are at least 200 miles apart.  This design ensures that if one of our locations suffers a disruption in service, systems at an alternate location can be used to continue to provide service.

Should there be an event that prevents Citizens Commerce National Bank from having access to a building, because of a disruption to the building, a city, or even an entire region (i.e. Pandemic), we can rely on the systems and or personnel in the other location(s) to allow us and our customers to continue to conduct business either without interruption or within a few minutes.

Citizens Commerce National Bank’s BCP also consists of recovery/contingency plans and teams.  The plans are designed to address various scenarios including incidents at a specific business location, another Citizens Commerce National Bank location, as well as when a technology or other service provider stops working for some reason.  Whatever the event, our plans are designed to enable us to be back in operation within 24 hours or less.

Recovery teams are in place to address the immediate response to an incident and the management of the situation from the time the incident occurs until the matter is resolved.  Team members are assigned specific responsibilities within each plan type.

In creating our BCP, we do assume that the locations we have identified, as “pre-designated alternative sites” are available, that we have sufficient personnel, and those external organizations, such as government agencies and market systems, are operational.  If any of these assumptions is in error, our business could be disrupted until matters are resolved.

Nevertheless, there can be no assurance that service will continue without interruption in certain circumstances, such as a regional blackout, a natural disaster or a terrorist attack.  However, in the unlikely event that Citizens Commerce National Bank has determined that it cannot resume operations within a reasonable amount of time, Citizens Commerce National Bank will provide as much advance notice as possible regarding its ongoing operations.

Preparation
Although Citizens Commerce National Bank is confident that customers will continue to have access to their accounts in the event of a significant business disruption, it is possible that there may be some temporary disruption or change in the manner in which you can access your account.  Citizens Commerce National Bank will notify customers of any such changes or disruptions by posting a notice on the Bank’s Web site or through a message on its telephone system.

To best prepare for such contingencies we suggest that you become familiar with the various means through which you can access your account including:

• Debit / ATM Card
• Online at www.citizenscommerce.com
• By telephone, 1-800-915-2617
• Local Citizens Commerce National Bank offices

Program/Plan Testing and Updating
While no BCP can eliminate all risk or delay resulting from an unplanned business interruption or disruption in service, Citizens Commerce National Bank does conduct regular assessments, updates and testing our plans annually to ensure that we have taken the steps necessary to protect our customers.

Additionally, the BCP is updated on an as-needed basis as business processes, technology, or staff change.  This document will not necessarily be re-sent to you, but we do post general and updated information about our BCP on our Web site.