ONLINE BANKING DISCLOSURE

www.firstflorida.bank

This disclosure contains information about terms, fees, and interest rates for some of the accounts we offer.

Disclosure Relating to Electronic Delivery - Online Banking Agreement.

Prior to using THE BANK's Online Banking, you must affirmatively consent to the terms of our Online Banking Agreement ("Agreement"). The Online Banking permits you to electronically initiate account transactions and communicate with THE BANK (the "Bank"). This Agreement contains the terms that govern your use of Online Banking. You can agree to the terms of this Agreement by signing at the end of this disclosure.

Prior to consenting to this Agreement you must be informed of:

Records Available - All records normally provided in writing may be provided electronically if you have affirmatively consented to receive such records electronically and you have not withdrawn such consent.

Receiving a Paper Copy - You have the right to receive a paper copy of this Agreement and/or all future notices. You may request a paper copy of this Agreement and/or all future notices at no fee in one of the following ways: send an electronic mail message ("E- mail") with your name and e-mail address to info@firstflorida.bank, call us at 850-269-1201 or write to us at P.O. Box 128, Destin, FL 32540, C/O Customer Service with your name and mailing address. Be sure to state that you are requesting a copy of the agreement/record/notice.

Withdrawing Your Consent to Receive Notices Electronically - You can contact us in any of the ways described in the preceding paragraph to withdraw your consent to receive any Agreements and/or future notices. If you withdraw your consent, we will send all future notices to you in paper form, at an additional fee. A consumer's withdrawal of consent shall be effective within a reasonable period of time after receipt by the institution. Failure, on the part of the institution, to provide adequate notice of changes in hardware and/or software specifications can be treated as a withdrawal of consent by the consumer without the imposition of fees.

Notifying Us of a Change in your E-mail Address - You must notify us of any change in your e-mail address by logging on to Online Banking, click the "online forms" tab, then click the "address change request" or write to P.O. Box 128, Destin, FL 32540, C/O Customer Service and give us your name and your new e-mail address.

Hardware and Software Requirements - In order to use Online Banking and to access, receive and retain notices electronically, you must provide at your own expense all necessary telephone lines, Internet or other connections and equipment needed to access Online Banking and to receive Notices electronically. Your computer must meet the following minimum requirements: an Internet web browser with capabilities to support a minimum 40 to 128 bit encryption (AOL, Safari version 8.0 or above, Internet Explorer version 11.0 or above, are examples). The minimum operating system for Mobile Banking are iOS 8.0 or higher for Apple devices and 4.1 or higher for Android devices. You confirm that your computer and/or mobile device will meet these specifications and requirements and will permit you to access and retain any notice electronically each time you access and use Online Banking.

Change in Hardware and/or Software Specifications - We will give you notice of any change of the previously disclosed specifications and/or requirements if the proposed change will adversely affect your ability to access and retain subsequent electronic notices from us.

Nothing in this agreement affects the content or timing of disclosures to be provided by any other statute, regulation or other rule of law. If any law requires verification or acknowledgement of receipt of such notice or disclosure, the notice or disclosure may be provided or made available electronically only if the method used provides verification or acknowledgements of receipt, whichever is required. Oral communication or a recording of an oral communication shall not qualify as an electronic record for the purposes of consent to receive

ELECTRONIC FUNDS TRANSFER AGREEMENT AND DISCLOSURES

This form complies with federal and Florida law. It applies to our electronic fund transfer (EFT) services. Electronic funds transfers are electronic transfers of money to or from your deposit account with us. This form states your and our rights and responsibilities for electronic fund transfers. In this form, the words "you" and "your" mean each and all who sign as applicants and any users of the service. The words "we", "us" and "our" mean the Financial Institution. The abbreviation "PIN" or word "code" means a personal identification number.

ONLINE BANKING:

Types of Transactions: You may access certain account(s) you maintain with us by computer using your assigned user ID and password by accessing the online banking service. You may use the online banking service to perform the following functions:

Fees for Online Service: There is no fee for banking online with us.

MOBILE BANKING:

Types of Transactions: You may access via mobile banking certain accounts {s) you have with us that are set up online by using your assigned user ID and password. You can perform the following functions from your mobile device:

Fees for Mobile Banking: There is no fee for mobile banking with us, other than access charges imposed by your carrier.

ATM Card

Types of Transfers: You may use the automated teller machine (ATM) card and personal identification number (PIN) issued to you to initiate transactions at ATMs of ours, ATMs within the networks identified on your card and such other facilities as we may designate from time to time. Unless you specify a different account during Automated Teller Machine (ATM) transactions, your Primary Account will be used for your transactions. Your Primary Account number and information may be obtained from the ATM Request Form. At present you may use your card to (some of these services may not be available at all ATMs):

Limitations on Frequency and Amount:

Fees for ATM Transactions:

Other ATM Fees: When you use an ATM not owned by us, you may be charged a fee by the ATM operator or any network used (and you may be charged a fee for a balance inquiry even if you do not complete a fund transfer).

ATM SAFETY TIPS

As issuers of Automated Teller Machine (ATM) access devices, we have provided for your information a list of safety precautions regarding the use of automated teller machines. Please read the following safety tips:

Government Direct Deposit Form

Types of Preauthorized Transfers: You may arrange for us to complete the following preauthorized transfers to your deposit accounts:

Fees:

Preauthorized Debit Form

Types of Preauthorized Transfers: You may arrange for us to complete the following preauthorized transfers to or from your deposit accounts:

Fees:

MasterCard Debit Card

Types of Transactions/Transfers: You may use the card and PIN issued you to pay for purchases from merchants who have agreed to accept the card at Point of Sale (POS) terminals within the networks identified on your card and such other terminals as the Bank may designate from time to time. Point of Sale (POS) transactions will be deducted from your Primary Account. Point of Sale (POS) transactions involving a refund will be credited to your Primary Account. You may also use the card to pay for purchases from merchants that accept the POS debit card with a MASTERCARD symbol. MASTERCARD is a registered trademark of MASTERCARD International. You may use the automated teller machine (ATM) card and personal identification number (PIN) issued to you to initiate transactions at ATMs of ours, ATMs within the networks identified on your card and such other facilities as we may designate from time to time. Unless you specify a different account during Automated Teller Machine (ATM) transactions, your Primary Account will be used for your transactions. At present you may use your card to (some of these services may not be available at all ATMs):

Limitations on Frequency and Amount:

Fees:

Other ATM Fees: When you use an ATM not owned by us, you may be charged a fee by the ATM operator or any network used (and you may be charged a fee for a balance inquiry even if you do not complete a fund transfer.

Other EFT Transactions.

You may access certain account(s) you maintain with us by other EFT transaction types as described below.

Electronic Check Conversion. You may authorize a merchant or other payee to make a one-time electronic payment from your account using information from your check to pay for purchases or pay bills. Electronic check conversion is a payment process in which a merchant or other payee (after obtaining your authorization) uses your check to gather routing, account, and check number information to initiate a one-time EFT. When information from your check is used to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day you make your payment. This type of EFT transaction involving a consumer account is covered by the Electronic Funds Transfer Act and this disclosure. A description of the transaction will appear on your statement.

Re-presented Check Transactions and Fees. You may authorize a merchant to electronically collect a fee associated with the re-presentment of a check that is returned due to insufficient or unavailable funds. The resulting fee transaction if debited as an EFT from a consumer account is covered by the Electronic Funds Transfer Act and this disclosure. When a merchant re-presents a check electronically, that transaction is not covered by the Electronic Funds Transfer Act or this disclosure. A description of the transaction will appear on your statement.

The following limitations may be applicable to your accounts, except as otherwise provided by law:

The zero liability limit described below only applies to debit cards that are United States issued MasterCard Consumer Cards for transactions processed through a MasterCard network or, for ATM transactions, a Plus network. The zero liability limit described below does not apply to: (a) other types of MasterCard commercial debit cards that are not VISA Business Cards; (bl transactions using your personal identification number that are not processed through a MasterCard network; and (c) ATM transactions which are not sent over MasterCard or Plus networks.

Tell us AT ONCE if you believe your MASTERCARD debit card has been lost or stolen or if you believe any unauthorized transactions have been made using your MASTERCARD debit card. Your liability for unauthorized MASTERCARD debit card transactions that are processed through a MASTERCARD or Plus network, as applicable, will be zero dollars ($0.00). However, to the extent allowed under applicable law (see for example the Liability for Unauthorized Transfers paragraph below) we may hold you liable for the entire amount of an unauthorized transaction if we find, based on substantial evidence, that you have been grossly negligent or fraudulent in the handling of your deposit account or MASTERCARD debit card.

NON-MASTERCARD DEBIT TRANSACTION PROCESSING:

We have enabled non-MasterCard debit transaction processing. This means you may use your MasterCard-branded debit card on a PIN-Debit Network (a non-MasterCard network) without using a PIN.

The non-Visa Debit Network(s) for which such transactions are enabled are: NYCE, AGGN, and PLUS networks.

Examples of the types of actions that you may be required to make to initiate a MasterCard transaction on your MasterCard-branded debit card include signing a receipt, providing a card number over the phone or via the Internet, or swiping the card through a point-of-sale terminal.

Examples of the types of actions you may be required to make to initiate a transaction on a PIN-Debit Network include initiating a payment directly with the biller (possibly via telephone, Internet, or kiosk locations), responding to a logo displayed at a payment site and choosing to direct payment through that network, and having your identity verified using known information derived from an existing relationship with you instead of through use of a PIN.

The provisions of your agreement with us relating only to MasterCard transactions are not applicable to non-MasterCard transactions. For example, the additional limits on liability (sometimes referred to as MasterCard's zero-liability program) and the streamlined error resolution procedures offered on MasterCard debit card transactions are not applicable to transactions processed on a PIN-Debit Network.

MasterCard Rules generally define PIN-DEBIT NETWORK as a non-MasterCard debit network that typically authenticates transactions by use of a personal identification-number (PIN) but that is not generally known for having a card program.

In addition to the limitations set forth above. The following limitations may be applicable to your accounts:

Liability for Unauthorized Transfers. Tell us AT ONCE if you believe your card, ATM PIN, POS card or PIN has been lost or stolen or if you believe that an electronic fund transfer has been made without your permission using information from your check. Telephoning is the best way of keeping your possible losses down. You could lose all the money in your account (plus your maximum overdraft line of credit). If you tell us within sixty (60) days after you receive a statement that shows any transfers that you did not make, you can lose no more than $50.00 if your card is lost or stolen and someone used your card without your permission. Also, if your statement shows transfers that you did not make, including those made by card code or other such means, tell us at once. If you do not tell us within sixty (60) days after you receive the statement, you may not get back any money lost after the sixty (60) days if we can prove that we could have stopped someone from taking the money if you had told us in time. If a good reason (such as a long trip or a hospital stay) kept you from telling us, we will extend the time periods. If you believe that your card or code has been lost or stolen or that someone has transferred or may transfer money from your account without your permission, call 850-269-1201, or write us at First Florida Bank, PO Box 128, Destin, FL 32540. You should also call the number or write this address if you believe a transfer has been made using the Information from your check without your permission.

Illegal Transactions- You may not use your ATM, POS, or Debit Card, or other access device for any illegal or unlawful transaction, and we may decline to authorize any transaction that we believe poses an undue risk of illegality or unlawfulness. Notwithstanding the foregoing, we may collect on any debt arising out of any illegal or unlawful transaction.

Business Days- For purposes of these electronic funds transfer disclosures, our business days are Monday through Friday. Holidays are not included.

Stop Payments on ATM, POS, or Debit Card Transactions- You may not place a stop payment order on any ATM, POS, or debit card transaction.

Documentation:

Periodic Statement. You will get a monthly account statement from us, unless there are no transactions in a particular month. In any case you will get a statement at least quarterly. You will get a quarterly statement from us on your savings account if this is the only account you have and the only possible electronic transfer to or from the account is a preauthorized deposit.

Terminal Receipt. You can get a receipt at the time you make a transfer to or from your account using an ATM or a POS terminal. However, receipts for transactions of $15.00 or less may not always be available.

Direct Deposits. If you have arranged to have direct deposits made to your account at least once every sixty (60) days from the same person or company, you can call us at 850-269-1201 to find out whether or not the deposit has been made.

Our Liability for Failure to Make Transfers. If we do not complete a transfer to or from your account on time or in the correct amount according to our agreement with you, we will be liable for your losses or damages. However, there are some exceptions. We will NOT be liable for instance:

In Case of Errors or Questions about Your Electronic Transfers. Telephone us at 850-269-1201, or write us at First Florida Bank PO Box 128, Destin, FL 32540 as soon as you can, if you think your statement or receipt is wrong or if you need more information about a transfer listed on the statement or receipt. We must hear from you no later than sixty (60) days after we sent the FIRST statement on which the problem or error appeared.

If you tell us orally, we may require that you send us your complaint or question in writing within ten (10) business days.

We will determine whether an error occurred within ten (10) business days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to forty five (45) days to investigate your complaint or question. If we decide to do this, we will credit your account within ten (10) business days for the amount you think is in error, so that you will have the use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it within ten (11) Business days, we may not credit your account.

If a notice of error involves an electronic fund transfer that occurred within thirty (30) days after the first deposit to the account was made, the error involves a new account. For errors involving new accounts, point of sale debit card transactions, or foreign-begun transactions, we may take up to ninety (90) days to investigate your complaint or question. For new accounts, we may take up to twenty (20) business days to credit your account for the amount you think is in error.

We will tell you the results within three (3) business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.

If a notice of error involves unauthorized use of your point of sale debit card with the MASTERCARD logo when it is used as a MASTERCARD point of sale debit card, we will provide provisional credit within five (5) business days after you notify us instead of within ten (10) or twenty (20) business days. We may withhold providing this accelerated provisional credit, to the extent allowed under applicable law, if the circumstances or account history warrants the delay.

[MASTERCARD is a registered trademark of MASTERCARD International.]

Confidentiality:

We will disclose information to third parties about your account or the transfers you make:

Personal Identification Number (PIN) - The ATM PIN or POS PIN is for security reasons. The numbers are confidential and should not be given to anyone else or listed on the card. You must keep your numbers safe. You agree not to give your ATM PIN or POS PIN to anyone who cannot sign on your accounts.

Notices- All notices from us will be effective when we have mailed them or delivered them to your last known address on our records. Notices from you will be effective when we receive the notice at our telephone number or address shown in this Agreement. We may change the terms and conditions for any EFT service. We will mail notice to you at least twenty one (21) days before the effective date of any change, as required by law. Use of EFT service is governed by regulations and any future changes to those regulations.

Enforcement- If you or we bring a legal action to enforce this Agreement or to collect amounts owing as a result of any Account transaction, the party who wins will receive reasonable attorneys' fees and costs, including fees on any appeal, to the extent allowed by law.

Cancellation of ATM and POS Services- You agree that we may cancel this Agreement and your use of the ATM Card or POS services, if:

Service is cancelled the first business day after we receive your written notice. Cancelling this Agreement will not affect your or our rights and responsibilities under this Agreement for transactions begun before the agreement is cancelled.

Preauthorized Electronic Fund Transfers

Stop Payment Rights- If you have told us in advance to make regular electronic fund transfers out of your account(s), you can stop any of these payments. Here's how: You must call us at 850-269-1201, or write us at First Florida Bank PO Box 128, Destin, FL 32540 in time for us to receive your request three (3) business days or more before the payment is scheduled to be made. If you call, we may also require you to put your request in writing and get it to us within fourteen (14) days after you call. If you don't, your stop payment will not bind us after fourteen (14) days. We will charge you $30.00 fee for each stop payment order you give.

Notice of Varying Amounts- If these regular payments may vary in amount, the person you are going to pay will tell you, ten (10) days before each payment, when it will be made and how much it will be. You may choose instead to get this notice only when the payment would differ by more than a certain amount from the previous payment, or when the amount would fall outside certain limits that you set.

Liability for Failure to Stop Payment of Preauthorized Transfers- If you order us to stop one of these payments three (3) business days or more before the transfer is scheduled, and we do not do so, we will be liable for your losses or damages.

Delay

There may be a delay between the time you make a deposit and when you can withdraw the money. You should review our Funds Availability Policy to find out when you can withdraw money that you deposit at ATMs.

Completing Transactions

We refuse to complete a transaction:

Currency Conversion and International Transactions

When you use your MasterCard-branded debit card at a merchant that settles in currency other than US dollars, the fee will be converted into the US dollar amount. The currency conversion rates used to determine the transaction amount in US dollars is either a rate selected by MasterCard from the range of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from the rate MasterCard itself receives, or the government-mandated rate in effect for the applicable central processing date. The conversion rate in effect on the processing date may differ from the rate in effect on the date the transaction occurred or the date the transaction is posted to the cardholders account. . MasterCard USA charges us a .8% International Service Assessment on all international transactions, regardless of whether there is a currency conversion. If there is a currency conversion, the International Service Assessment is 1% of the transaction. In either case, we pass this international transaction fee on to you. An international transaction is a transaction where the country of the merchant is outside the USA.

Complaint Policy

At First Florida Bank we are committed to building lifetime relationships with our customers by providing superior customer service. When you have a concern or complaint, we encourage you to tell us about it by following our Complaint Resolution Process.

Step One
The first step to resolving a complaint is to contact us directly. Our Compliance Officer will act promptly to resolve your complaint, and, as appropriate, escalate your complaint to our management team.

You may contact our Compliance Officer by calling us at 850-269-1201.

Alternatively, if it is more convenient, you may fax your complaint to 850-200-4747 or write to us at:
First Florida Bank
PO Box 128
Destin, Fl., 32540
Attn: Compliance Officer

Step Two
If your complaint is not resolved to your satisfaction through our Compliance Officer, our staff will offer to elevate your complaint to a member of our management team and have him or her contact you. Alternatively, if you prefer to elevate your concern yourself, you may contact us by calling us at 850-269-1201 and ask to speak directly to a manager. The manager will make every effort to resolve the issue immediately, investigate your complaint, communicate your complaint to senior management, and ensure that you receive a prompt response or let you know when you can expect a response from us.

If you have a complaint about any obligation of First Florida Bank under a consumer provision of the consumer protection regulations, you may file a written complaint with our regulator at:
Mail:
Federal Reserve Consumer Help
PO Box 1200
Minneapolis, MN 55480

These agreements may be amended from time to time and notice of such change will be provided to you by us as may be required by applicable law.

Termination of Service

We may cancel, terminate, or suspend any of the Services (including, without limitation, any and/or all pending or scheduled Service transactions) at any time in our discretion, for any reason or for no reason, without notice to you, except as required by applicable law or regulation. To the fullest extent permitted by law, you agree that we shall have no liability to you or to any third party in the event we cancel, terminate, or suspend any Service (or any Service transaction), or in the event we exercise any of our other rights or remedies under, relating to, or arising out of this Agreement. No termination, cancellation, or suspension of this Agreement or any Service (or any Service transaction) for any reason (including, without limitation, cancellation of any Service by you or by us) shall relieve you of any liability for obligations which have accrued prior to the effective time of such termination, cancellation or suspension or for obligations and duties under this Agreement which by their nature or by express provision are intended to survive. Without limiting the foregoing provisions, you acknowledge and agree that we may consider your enrollment in any Service inactive or dormant after a certain period of time (generally six months) set from time to time by us during which you have not logged in to the Service application. Once your enrollment has been placed on inactive or dormant status, Service transactions may be declined, you may not be able to access the Service, and/or you may be required to re-enroll in the Service in order to continue using it.

Please read this agreement and disclosure statement carefully because it tells you about your rights and responsibilities for EFT transactions processed using the Banks Online Banking. You should keep this agreement and disclosure statement for future reference.

BY CLICKING BELOW You consent to the electronic delivery of the Online Banking Agreement and other notices or disclosures relating to the Agreement. You confirm that you are able to access information in an electronic form and you also agree that the institution does not need to provide you with an additional paper (non-electronic) copy of the Agreement unless specifically requested. You agree to the terms and conditions of all applicable notices and disclosures.