GENERAL PRIVACY PRINCIPLES

First Federal Bank of California does not sell client information to others. We share your information only under certain permitted exceptions.  Examples include information given to our data processing services provider in order to process your transaction, or information given to another financial institution solely in order to offer services to you which we do not offer directly. The following are other general principals we follow to protect your privacy.

PRIVACY STATEMENT

First Federal Bank of California understands that the protection of confidential information is a critical aspect of good client service. Whether you are a long-time broker, a new broker, or are just considering doing business with us, we want you to know that your nonpublic personal information will be treated with respect for your privacy. This policy covers the limited disclosure of personally identifiable information about our brokers. This policy is provided to you as required by the federal financial privacy law regulations.

Recognition of our clients’ expectation of privacy. We know that your financial information is personal and we are committed to protecting your privacy. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We will answer any questions you may have about the handling of sensitive information regarding your accounts.

Maintenance of accurate client information. We have procedures to maintain accurate, current, and complete information about your business relationship with us, and we correct any inaccuracies promptly. To help us maintain accurate records, please contact your Account Executive to report any incorrect information regarding your name, address, or other personal information.

Limiting employee access to confidential information. We maintain policies and procedures to ensure that access to your personally identifiable information is limited to employees with a business reason for knowing such information. We train our employees in the importance of confidentiality and privacy. Our Code of Conduct emphasizes the importance of keeping this information confidential, and we enforce these employee responsibilities.

Protection of confidential information. First Federal Bank of California has established security procedures to safeguard your personal and banking information from unauthorized access. We regularly review and test our technology to protect the integrity of our security systems. You can help with this process by regularly reviewing your account and loan statements, and by contacting us immediately if you believe that someone has unauthorized access to your personal information.

We collect and disclose broker information on a limited basis in accordance with the following practices:

Limited collection of client information. We collect only that information which we believe will help us to serve your financial needs. We collect information about you from the following sources:

- Information we receive from you on applications or on other forms
- Information about your transactions with us or others
- Information we receive from a consumer reporting agency

We may disclose the following kinds of information about you to limited categories of parties (who are described in the next section):

- Information we receive from you on applications or other forms, such as your name, address, social security number or business TIN, assets and income
- Information about your transactions with us or others
- Information we receive from a consumer reporting agency

Legally permitted disclosures. We may disclose the information that we collect to others on a limited basis. We do not sell or otherwise provide client information to catalogs, direct mail companies, magazines, or other non-financial service providers.

Disclosure of nonpublic personal information about our brokers or former brokers is permitted under some circumstances, such as to selected credit reporting agencies, when it is legally required (such as in response to a subpoena), and to prevent fraud or to comply with a legally permitted inquiry by a government agency or regulator. We also disclose information when authorized by you, to help complete a transaction you initiated.

We are permitted to disclose your information to outside service companies who we hire to perform business services for us. We provide only that information necessary to perform the job, and we require them to maintain security and confidentiality of the information provided. These service companies are not permitted to use any information for any purpose other than in providing the services we have requested.

We also are permitted to provide information to others under joint marketing arrangements. Under these arrangements, we select other companies to provide products and service that we do not offer. We provide them with only with the limited information necessary to offer these products to you. We are selective in choosing these companies. They are obligated to keep the information we provide to them confidential, and use the information only to provide the services we have requested.

Information we share with our affiliates

First Federal Bank of California strives to provide a varied array of financial services at a competitive price and with exceptional service. To assist in that effort, we may from time to time share information among members of our corporate family (our "affiliates") on a confidential basis. This allows us to offer easier access to new or enhanced products, special promotional offers, or other benefits that you might not otherwise know about.

You may instruct us not to share information we obtain from others (such as credit reports) among our affiliates, although we may continue to share information about our transactions or experiences with you.  Under the Fair Credit Reporting Act, you may tell us that you do not want us to share this non-experience information within the First Federal family of companies by contacting First Federal Bank of California, Residential Lending Division, 6053 W. Century Blvd Suite 400, Los Angeles, CA 90045, Attn: Compliance, (800) 778-4332. Please be aware that we may continue to share transaction and account experience information, as well as other general information, with affiliated companies.  Even if you choose to opt out, you will continue to receive statements, statement inserts, and other account information. 

Supplemental Online Privacy Guidelines

Our Privacy Statement explains in general how we protect and, on a limited basis, disclose client information. There is additional information you should know when you visit our website. 

Protecting Information Online
As a current broker or as a visitor, any information you provide to us at www.firstfedwholesale.com is protected as described below.

Protection of Online Personal Information
When you sign up online, you must provide personal information that is necessary in order to process your application and transactions. To ensure that your information remains confidential, the information is sent to us in a "secure session" established with our data processing services provider. After you submit your online transaction, it is necessary that you end your online session before leaving your computer in order to ensure the privacy of your information.

We will keep this online information, and may use it to offer you products and services, as described in our Privacy Statement.

Handling of E-Mail
When you send us an e-mail, we keep your message, your address and our response in order to handle any follow-up questions, as well as to satisfy legal and regulatory requirements. We may, from time to time, contact you at your e-mail address to inform you of products, services and other benefits we offer.

You should be aware that regular non-encrypted internet e-mail is not secure. If we give you a First Federal Bank of California e-mail address, this address is provided for inquiries of a non-sensitive and non-confidential nature. If you conduct online transactions and require secure online transmission of information to us, such as specific questions regarding your account, you should use the secure forms for contacting us provided within the online banking pages of our web site. These inquiries will be secure and use encryption. You may also contact us by telephone or U.S. mail. 

No Information Gathering in Planning Tools
The calculators in our site that help you make financial decisions are hypothetical, "what if" scenarios. Examples include the mortgage principal and interest calculator and savings goal calculator. These planners do not capture personal information you may provide.

Encryption
When you provide personal information on our web site, the information is encrypted (scrambled) so that it can be read by First Federal Bank of California but not by others. For more information on our encryption, click here.

Information Gathering and Retention
Some information, such as your e-mail address or account number, is collected and retained by us in order to perform services for you as requested. If you browse our web site without providing that information, personal information such as your e-mail address is not collected. We gather and analyze data regarding usage of our web site, including number of "hits", pages visited, etc., to evaluate the effectiveness of our web site and to improve our services.

Access to Web Site by Children
The responsibility to protect a child’s identity and privacy is one that is shared by the online provider and the child’s parents. Please be aware that First Federal Bank of California does not intentionally market to children, nor does it intentionally solicit data from children.

Caution Against "Spoofers"
"Spoofing" is the term used to describe the creation of a close-to-identical image of First Federal Bank of California’s web site in order to lure users to the phony site and capture their confidential information. For example, the fraudulent site could be reached by a link containing a slight misspelling of our address (such as flrstfedca.com). You can make sure that you are not a victim of "spoofing" by carefully reviewing the site when you arrive there to ensure that the address does in fact say www.firstfedwholesale.com.

Changes
Our Privacy Statement may change from time to time, so please check www.firstfedwholesale.com for the most up-to-date information.

Thank you.