The Odessa Employees’ Credit Union is committed to meeting all the financial needs of its members without compromising the valued relationship we have with our members. The Directors, management and staff of the Credit Union acknowledge that our member’s trust and confidence in the Credit Union is our highest priority. In their daily transactions and dealings with us, our members furnish us sensitive and confidential information. We are committed to protecting our member’s privacy and it is our stated intent to comply with the NCUA Privacy Rules and other applicable privacy provisions. To ensure that our members continue their trust in our Credit Union, we adopt the following policy.

The Credit Union shall comply with all NCUA Privacy Rules and all applicable state privacy laws affecting us. The Credit Union’s Compliance Officer, the Manager, shall be responsible for ensuring that all Directors, management and staff are properly trained in the various privacy laws affecting the Credit Union. The Compliance Officer shall continuously monitor privacy regulations. The President/CEO of the Credit Union shall ensure that the Credit Union has fully complied with all privacy laws.

No Credit Union employee shall request information from a member unless that information is necessary to conduct or complete a transaction, process an application, or is for business purposes.

The Credit Union shall only disclose the information it collects from its members and former members to affiliates of the Credit Union, transaction processors, other financial institutions and service providers to ensure that those parties follow allowed by law, in accordance with 12 CFR Parts 716.13, 716.14, and 716.15.

The Credit Union shall enter into joint agreements with other financial institutions and service providers to ensure that those parties follow our strict confidentiality procedures and do not use our member’s personal information for any purposes other than the purpose of our agreement with them.

The Credit Union shall restrict access to our member’s information to those employees who need to know that information to provide products or services. The Credit Union shall maintain physical, electronic and procedural safeguards that comply with federal and state regulations in order to protect our member’s personal information.

The Credit Union shall create and disclose a privacy notice to all credit union members upon establishing a membership with the Credit Union and at least annually thereafter.

Adopted this 8^TH day of March, 2001.

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates, or others;
• Information we receive from a consumer-reporting agency.

We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

We do not disclose any nonpublic personal information about our members and former members to anyone, except as permitted by law.

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

Board of Directors and Management

March, 2001