Disclosures

CONSENT TO RECEIVE ELECTRONIC DOCUMENTATION

FUNDS AVAILABILITY POLICY DISCLOSURE

EXCESSIVE OR LUXURY EXPENDITURES POLICY

1. Purpose
   The purpose of this policy is to establish parameters and internal controls governing the expenditures of Freedom First Federal Credit Union (together with its subsidiaries and controlled affiliates, referred to hereafter as the Credit Union). Expenditures of the Credit Union should be customary, prudent, consistent with applicable laws and regulations, and reasonably related to the Credit Union’s business objectives and needs. This policy identifies expenditures that are excessive or luxury expenditures, creates processes that are reasonably designed to eliminate such expenditures, and establishes accountability for compliance. Routine operating expenses, capital expenditures, and other reasonable expenses are not prohibited by this policy.
   
2. Authority
   The Credit Union has authority to provide compensation and benefits that are reasonable. This policy establishes a prohibition on expenditures that are excessive or luxury expenditures as required by the Department of the Treasury’s Emergency Capital Investment Program regulations (31 CFR Part 35), and as may be required by other statutes and regulations.
   
3. Responsibility
   This policy is the responsibility of the Credit Union’s board of directors (“Board”). The Board has approved this policy. The Board and internal auditors will review this policy no less than annually.
   
4. Scope
   This policy applies to all employees, officers, and directors of the Credit Union with regard to any expenditure of the Credit Union. In making any expenditure on behalf of the Credit Union, employees, officers, and directors should consider whether the expenditure is an excessive or luxury expenditure that is prohibited under this policy.
   
5. Excessive or Luxury Expenditures
   “Excessive or luxury expenditures” means excessive expenditures on any of the following to the extent not reasonable or appropriate expenditures for business development, staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the Credit Union’s business operations:
   
   1. Entertainment or events. This category includes fees, dues, tickets costs related to social, athletic, artistic and dining clubs, activities, celebrations or other events, and similar expenditures. Expenditures for charitable contributions and charitable events are not prohibited under this policy. Entertainment or events expenditures, in an amount less than $1,000 per instance, and $10,000 on an annual aggregate basis per individual, are exempt from this policy.
   2. Office and facility renovations. Office and facility renovations. This category includes costs and allowances for office renovation, including expenditures related to furniture, art, office personalization, interior finishing, design and decoration, and similar expenditures. Office and facility renovations expenditures, in an amount less than $20,000 per instance, and $20,000 on an annual aggregate basis per individual, are exempt from this policy.
   3. Aviation or other transportation services. This category includes charter fees, tickets, slip or docking fees, vehicle installment payments, reservation and travel agent expenses, and similar expenditures associated with transportation services (e.g., airline, train, rental cars, or vans). Mileage reimbursable according to current Internal Revenue Service mileage rates is exempt from this policy. Transportation services, in an amount less than $2,000 per instance, and $15,000 on an annual aggregate basis per individual, are exempt from this policy. The CEO may establish or delegate to an appropriate executive officer the authority to establish processes for reimbursement of reasonable travel expenditures, which processes must be reviewed by executive management no less frequently than annually.
   4. Tax gross-ups. This category includes any reimbursement of taxes owed with respect to any compensation. This category does not apply to tax equalization agreements for employees subject to tax from a non-U.S. jurisdiction.
   5. Other similar items, activities, or events for which the Credit Union may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses. Expenditures related to other items not listed in the preceding categories, in an amount less than $2,000 per instance, and together with all expenditures permitted under this policy, may not exceed $10,000 on an annual aggregate basis per individual, are exempt from this policy . For the avoidance of doubt, reasonable capital investments in technology, equipment, and similar items that expand the long-term capability of the Credit Union to provide products and services to its customers and community are not excessive or luxury expenditures. The CEO may establish or delegate to an appropriate executive officer the authority to establish processes for the evaluation and approval of expenditures in the preceding categories that are not luxury or excessive expenditures and that are not otherwise exempt from this policy. These processes must be reviewed by executive management no less frequently than annually, as well as any additional threshold expenditure amounts per item, activity, or event, or a threshold expenditure amount per employee receiving the item or participating in the activity or event under this policy. Such approvals must be reported to the board of directors (which may be in an appropriate summary form) no less frequently than annually.
6. Exceptions or Violations
   Any exception or violation of this policy must be promptly reported to the Credit Union’s (i) CEO, (ii) General Counsel, or (iii) officer designated with primary responsibility for overseeing the administration, monitoring, and compliance with this policy. Exceptions and violations must be reported to the Supervisory Committee no less frequently than annually, or more frequently as the nature and severity of violation may warrant. All employees, officers, and directors of the Credit Union must adhere to this policy and will be held accountable for compliance. Any employee or officer who violates this policy may be subject to disciplinary action up to and including termination of employment. Any employee or officer who has actual knowledge of a violation of this policy is required to report such circumstance to their supervisor or the Credit Union’s principal compliance officer or compliance group. The Credit Union prohibits retaliation against any employee or officer for making a good faith report of actual or suspected violations of the Credit Union’s code of conduct, laws, regulations, or other Credit Union policies, including this policy. A finding of retaliation against any such employee or officer may result in disciplinary action up to and including termination. Employees and officers may ask questions, raise concerns, or report instances of noncompliance with this policy and/or any of the existing underlying relevant policies by contacting the EthicsPoint Hotline.
   
7. Certification
   On an annual basis, for so long as the Credit Union is a participant in the “ECIP” Treasury program, the Credit Union will deliver to the Department of the Treasury a certification, executed by two senior executive officers (one of which must be either the CEO or CFO) certifying that (i) the Credit Union is in compliance with this policy and (ii) the approval of any expenditure requiring the prior approval of any senior executive officer, any executive officer of a substantially similar level of responsibility, or the board of directors (or a committee of such board), was properly obtained with respect to each such expenditure.
   

IMPORTANT CREDIT CARD DISCLOSURES

INTEREST RATES AND INTEREST CHARGES: