Online Banking Agreement and Disclosure

Transcription

1 Online Banking Agreement and Disclosure AGREEMENT This Online Banking and Online Banking Agreement ( Agreement ) contains the terms and conditions governing your use of WCU Credit Union s Online Banking program (WCU Homebanking). The Program is an Internet based service that will allow you to review and conduct financial transactions online. This Online Banking Agreement ( Agreement ) is a contract that establishes the rules, which cover your electronic access to your various accounts at WCU Credit Union Internet Banking Services. By using WCU Homebanking (Online Banking Services), you accept and agree to all of the terms and conditions in this Agreement. Please read it carefully. You should retain a copy of this Agreement. The first time you access your accounts through WCU s Homebanking (Online Banking) confirms your agreement to be bound by all the disclosures and agreements and acknowledges your receipt and understanding of this Disclosure and Agreement. This Agreement will be effective as of that same date. All transactions done on Online Banking are also subject to the terms of the specific deposit or loan account agreements and disclosures and the current service charges schedule (fee schedule). DEFINITIONS. (AS USED IN THIS AGREEMENT) We, our, us, and Credit Union mean WCU Credit Union. You, your, and member mean the accountholder authorized by the Credit Union to use Online Banking Services under this Agreement and anyone else authorized by that accountholder to exercise control over the accountholder s funds. Account or Accounts means your accounts at the Credit Union including loans, checking, savings and all other deposit and transaction accounts subject to this Agreement. Electronic Fund Transfers has the same meaning as in Regulation E (12 CFR1005) and includes ATM withdrawals, preauthorized transactions, point of sale transactions and transfers to and from your Accounts using telephone or Internet Banking Services. Account Transfer means any transfer of funds debited from or credited to your Account at the Credit Union through Electronic Fund Transfers or through the Credit Union s internal transfer between Accounts initiated through Online Banking Services. Internet Banking or Online Banking Services means the services provided pursuant to this Agreement (WCU Homebanking). Business Day means Monday through Friday, excluding federal holidays. Service Provider means Connect/PSI. Web Site means the Credit Union s website at ADDITIONAL SERVICES We may, from time to time, make additional services available through our Internet Banking Services. Our notification may be in the form of information posted on our Web Site and will be subject to the terms and conditions of and amendments to this Agreement unless we state otherwise. We will notify you of the availability and terms of these new services. By using these additional services when they become available, you agree to be bound by this Agreement and any amendments to it, and accept any additional instructions, procedures, terms, and conditions provided to you with respect to each of these new services as amendments to this Agreement. MODIFICATIONS WCU Credit Union Online Banking (Including Mobile Apps.) reserves the right to modify or discontinue, temporarily or permanently, the Services with or without notice to you. Such modifications may include establishing or changing limits concerning use of the Services, temporarily or permanently, including (i) any features, licensing terms, or other characteristics of any version of the Services that it releases, (ii) the amount of storage space you have on the Services at any time, and (iii) the number of times (and the maximum duration for which) you may access the Services in a given period of time. We reserve the right to make any such changes effective immediately to maintain the security of the system or Account Information or to comply with any Laws. You may reject changes by discontinuing use of the Services to which such changes relate. Your continued use of the Services will constitute your acceptance of and agreement with such changes. User access and use of the Services may be interrupted from time to time, including due to the malfunction of equipment, periodic updating, maintenance or repair of the Site and/or the Services or other actions that WCU Credit Union Online Banking (Including Mobile Apps.), in its sole discretion, may elect to take. Maintenance upon the Services may be performed from time to time resulting in interrupted service, delays or errors in the Services. WCU Credit Union Online Banking (Including Mobile Apps.) shall not be liable to you or any third party should we exercise our right to modify or discontinue the Services. ELECTRONIC DISCLOSURE AND CONSENT You agree that we may provide you with all disclosures, notices and other communications, about Online Banking Services including this Agreement and any future amendments, in electronic form. We will provide all future notices by posting them on the Web Site for a period of at least 90 (ninety) days. You may download or print the notices from your computer, if you have the proper hardware and software. At your request, we will provide you with a paper copy of any of the above documents without any fee. You have the right to withdraw this consent, but if you do so, we will immediately terminate your participation in Online Banking Services. You may obtain copies of any documents we provided electronically or withdraw your consent by contacting

2 us at (256) DISCLAIMER The Services provided by WCU Credit Union Online Banking (Including Mobile Apps.) are not intended to provide legal, tax or financial advice. The Services are not a financial planner, broker or tax advisor. The Services are intended to assist you in your financial organization and decision-making and are broad in scope. You should consult with your accountant or other financial professional who is fully aware of your circumstances in addition to using the Services. ONLINE BANKING ACCOUNTS AND SERVICES. You agree to use Internet Banking Services solely for the services described in this Agreement and solely in connection with each WCU Account on which you are authorized to conduct transactions or obtain information. ELIGIBLE ACCOUNTS Each WCU deposit or loan account, including lines of credit you have with us is called an Eligible Account. Eligible accounts include both Consumer Accounts and Commercial Accounts. A Consumer Account is an account held by a natural person(s) established primarily for personal, family, or household purposes. A Commercial Account is any other account. Eligible Accounts will include all Accounts on which the member is listed as an account owner or borrower. When a Primary Account Owner accesses Online Banking, that member will be able to view and access all linked accounts (cross accounts) for which the person is a joint owner. We reserve the right to limit the types and number of accounts eligible for Online Banking. ACCOUNT INFORMATION You may use the Online Banking Services to receive, download, store and print information that is routinely set forth in the statements for the Account, such as debits and credits made to the Account, amounts and item numbers for items drawn on the Account, and Account balances. Because the information made available to you is "raw data" furnished through the Service Provider and is subject to change, we cannot assure you of the accuracy or completeness of the information and expressly disclaim the same. You will still receive your usual periodic statement of account ("Account Statement") for each Account maintained with the Credit Union. Your Account Statement remains the Credit Union's official record of your Account balances and activity. ONLINE BANKING SERVICES You may use Online Banking Services for the following functions: - Obtain balance info for share, share draft, loan, money market, club, IRA and certificate accounts. - Review transaction history (including pending transactions) for share, share draft, loan, money market, club, IRA and certificate accounts. - Transfer funds to & from share, share draft, and Money Market accounts (including cross/linked WCU Accounts). - Schedule one-time or recurring transfers in the future (including cross-account transfers). - Make loan payments from your share, share draft, and Money Market accounts. - Determine if a particular item has cleared. - View, print and download images of recently paid checks drawn on your Accounts. - Verify the last date and amount of your payroll deposit. - Submit address changes. - View, print, save, or download account history or *account statements, or *tax documents. (*Available only to members who have signed up & agreed to terms/conditions for E-Statements through WCU Homebanking.) - Direct us to make payments from your Account to 3 rd parties (optional with a draft account, under separate Bill Pay agreement) ONLINE BANKING INITIAL SETUP Step 1 - Log In as a New User The first time you Log In, you will need to set up a New User Profile Visit Click on Online Banking Click on New User Enter Account #/User ID: Use your 5-Digit WCU Account number Enter PIN/Password: Use the last 4 digits of the primary account holder s Social Security Number. Step 2 - Verification You will be asked to verify your identity by entering the last 4-digits of the Primary account holder s Social Security Number, their zip code and their birth date. Step 3 - Change Password / User ID For security, you will be required to change your Password and User ID upon initial registration Enter the last 4-digits of the Primary account holder s Social Security Number.

3 Enter New Password: Must be 8 to 25 characters long Must contain both letters and numbers No symbols except for the underscore _ Passwords are case sensitive Cannot be your SSN or WCU account number or your User ID, or your , NOR any of your 3 previous passwords Re-enter New Password, then click Submit. Enter a New User ID (on the following page) Must be 5 to 25 characters long Must contain at least one letter and one number Must contain NO symbols Step 4 - Accept Online Banking Agreement You must accept the Online Banking Agreement to access Online Banking. This agreement also contains important information regarding estatements, enotices, Bill Pay and transfer information. Step 5 - Enhanced Log In Security MULTIFCATOR AUTHENTICATION QUESTIONS: You will be required to choose 3 Security Challenge Questions & Answers prior to completing a successful login to Online Banking for additional security. Step 6 - Verify your address when prompted. BILL PAYMENT SERVICES Included in the Online Banking Services is an optional service that allows you to direct us to make payments from your eligible deposit Account to a person or entity to which you wish a bill payment to be directed or is a person or entity from which you receive electronic bills, as the case may be. Our free Bill Pay system works just like an online checkbook. You control what bills are paid, payment date, and amount paid. Set up one time or recurring payments, expedite payments, send money online to another person, or edit payments as needed nothing comes out of your account until you say so. This is provided through our service entitled Bill Pay. This service is provided by us through our non-affiliate service providers. Any applicable fees may apply for the use of Bill Pay as provided in the separate Bill Payment Service Agreement which controls the Bill Pay service. Standard delivery of bills is free. Expedited options will incur charges. Transaction limits may apply. You are responsible for providing contact information for each payee of a Bill Payment transaction. You are also responsible for providing any changes to this contact information as soon as you are aware of them in order to prevent a loss. Using the Bill Payment service, you may only pay established payees with United States addresses. While payments to most payees can be made using the Bill Payment service, we reserve the right to refuse to make payments to certain payees, such as alimony, child support, tax and other court directed or government payments, fines or penalties. We are unable to process any payments to federal, state or local tax agencies. You may use the Bill Payment function of the Program using funds in one or more of the Eligible Consumer or Commercial Accounts that is a checking account. All payments are made from the designated Eligible Accounts each of which must be a checking account. We will process bill payment transfer requests only to those creditors the Credit Union has designated in the User Instructions and such creditors as you authorize and for whom the Credit Union has the proper vendor code number. We will not process any bill payment transfer if the required transaction information is incomplete. We will withdraw the designated funds from your share draft account for bill payment transfer by the designated cut-off time on the date you schedule for payment. We will process your bill payment transfer within a designated number of days before the date you are scheduled for payment. You must allow sufficient time for vendors to process your payment after they receive a transfer from us. Please leave as much time as though you were sending your payment by mail. We cannot guarantee the time that any payment will be credited to your account by the vendor. You are responsible for having sufficient funds on deposit to make payments in full on scheduled Payment Dates. If there are insufficient funds in your designated Eligible Account to make the payments you have authorized, we may either refuse to pay the item or we may make the payment and thereby overdraw your designated Eligible Account. In either event, you are responsible for any non-sufficient funds (NSF) and overdraft charges we may impose as stated in your depositor agreement. BILLPAY INITIAL SETUP Step 1 - Sign into WCU s Homebanking and select the Bill Pay tab. Step 1 - Accept the terms and conditions of the Bill Payment Service Agreement. Subsequently you will be able to activate Bill Pay Services. If you do not choose the Bill Pay service at this time, you may add the service later through the Online Banking Services. At the present time, you may use Bill Pay to: - Initiate bill payments through our Bill Pay service -See WCU s BillPay Agreement & Disclosure online at for full details. - There is no limit on the number of bill payments per day. - See Section 2 of WCU s EFT Agreement/Disclosure for transfer limitations that may apply to these transactions. MOBILE BANKING SERVICES

4 Mobile Banking is offered as an additional service to our Online Banking Services. You will be able to download an application on your phone that uses your phone s browser to access your Account. It is not intended to replace access to Internet Banking Services from your personal computer or other methods you use for managing your accounts and services with us. Mobile Banking allows you to access your account information and conduct a variety of other transactions on your mobile phone. In order to use the Mobile Banking, you must be enrolled to use the Internet Banking Services and then activate your mobile device on the Internet Banking Services. We reserve the right to limit the types and number of accounts eligible for Mobile Banking. We reserve the right to refuse to execute any transaction you request through Mobile Banking. We also reserve the right to modify the scope of the Mobile Banking Service at any time. -We do not guarantee functionality of the service on all mobile devices. At the present time, you may use Mobile Banking (Mobile Apps) to: - Obtain various account information related to any of your share, share draft, money market, club, IRA, loans, or Certificate accounts (including current and available balances, dividends posted, loan payment amounts) - Verify the last date and amount of your payroll deposit. - Determine if a particular item has cleared. - Transfer funds between share, share draft, money market accounts. (including cross-account transfers). - Make loan payments from your share, share draft, and Money Market accounts. - Access estatements & Tax Documents for the account you are logged in for. (Available only to members who have signed up & agreed to terms/conditions for E-Statements through WCU Homebanking.) - Account History available for viewing is limited to the past 90 days. MOBILE BANKING INITIAL SETUP You must be set up to use WCU Homebanking and have logged in at least once in order to access WCU s Mobile Banking / Mobile Apps. If you are NOT currently a WCU Homebanking User, please see the ONLINE BANKING INITIAL SETUP Section above for instructions on how to register for WCU Homebanking. Step 1 Register and Log In as a WCU Homebanking User Step 2 Go to the itunes Store or Google Play Store, search and download the WCU Mobile app for Android, iphone or ipad Step 3 Use your WCU Homebanking Login Credentials for your Login Credentials for WCU s Mobile Apps Step 3 The Check the address on file for the Primary Account Owner for a security code. The first time you Login to Mobile App, an with a security code will be sent to the primary address on file. Step 3 Enter this code in the app as requested. Once the code has been verified the app setup is complete. If you remove WCU s Mobile App from your device, you will be required to do this again if you re-install WCU s Mobile App). Remember Mobile App Account History available for viewing is limited to the past 90 days. Mobile Banking may not be accessible or may have limited use over some network carriers. We cannot guarantee and are not responsible for the availability of data services provided by your mobile carrier, such as data outages or out of range issues. You are responsible for the charges of any wireless service provider while using the service. You agree that you will contact us directly if you encounter any problems with Mobile Banking. We may modify the Mobile Banking service from time to time at our sole discretion. In the event of any modifications, you are responsible for making sure you understand how to use Mobile Banking as modified. You also accept responsibility for making sure that you know how to properly use your mobile phone and we will not be liable to you for any losses caused by your failure to properly use the Mobile Banking service or your mobile phone. You agree that, when you use Mobile Banking, you remain subject to the terms and conditions of your existing agreements with any unaffiliated service providers, including, but not limited to, your mobile service provider and that this Internet Banking Agreement does not amend or supersede any of those agreements. You understand that those agreements may provide for fees, limitations and restrictions which may impact your use of Mobile Banking (i.e. data usage charges imposed on you by your mobile service provider for uses of or interaction with Mobile Banking), and you agree to be solely responsible for all such fees, limitations, and restrictions. You agree that only your mobile service provider is responsible for its products and services. Accordingly, you agree to resolve any problems with your provider directly without involving us. The accounts that you access using the Mobile Banking service are subject to the terms and conditions of the deposit agreement for those accounts and the additional terms and conditions included in this Internet Banking Agreement. estatements and ELECTRONIC NOTICES When you register for online banking, you may consent to receive your periodic account statements online through our estatement service. You must provide a valid address and log in to Online Banking to receive estatement services. If you currently receive paper statements and wish to change to estatements, simply click on Online Services and select estatements. Your statement preference is then set going forward until we receive notification from you to change it, if applicable. Your estatements may include the periodic account and transaction activity for your deposit, loan and credit card accounts; notices for insufficient funds, certificate maturity, and other similar account notices; year-end tax statements for dividends earned and mortgage interest paid and any disclosures. estatements and notices are accessed by signing on to

5 Online Banking and clicking on the estatement button. We will send you an whenever a monthly statement, account notice, or tax form is available for review. You also have the option to download or print the documents for future reference. You have the right to request and receive your statements and other documents in paper form, and you may withdraw your consent to receive estatements at any time. In order to continue to receive estatements, you must keep your address updated with WCU at all times. If you are unable to view the estatement page by the next day, please contact WCU Credit Union.oth estatements and check images are displayed in Adobe Acrobat Reader, so you must have this application installed. If you do not currently have Adobe Acrobat Reader, you can download a copy free by going to To sign-up for E-Statements 1. Login to WCU Homebanking 2. Click on the Accounts tab 3. Click on estatements. 4. Verify your address on the screen 5. Read the disclosure/agreement 6. Click on I Consent at the bottom of the estatement Signup page to consent to accept statements electronically instead of by way of US mail. To view your estatement 1. Log into WCU Homebanking by entering your User ID and Password 2. Click the Accounts Tab 3. Select the estatement option TRANSFERS INTERNAL ACCOUNTS You may use our Online Banking Services to initiate Account Transfers between your WCU Accounts. Please ensure that you have sufficient funds to affect any funds transfers from your Accounts. We may at any time decline to execute any funds transfers that we believe may violate applicable law. LINKED ACCOUNT (CROSS ACCOUNTS) When you first set up your User Name/User ID & Password, we will link all of your eligible WCU Accounts. This includes all eligible account suffixes you are listed on as a primary or joint owner. If you open an additional eligible account/suffix at a later date, we will link your new account to the Online Banking Service. EXTERNAL TRANSFER (VIA BILLPAY SERVICE) External Transfer allows you to schedule transfers between WCU and other financial institutions or individuals through our BillPay Service. (See WCU s BillPay Service information section below). AUTHORIZATION. You expressly authorize us to debit the Account in the amount of any Account Transfer initiated through Internet Banking Services by you or your authorized agent. You agree that we may treat any such Account Transfer from an Account the same as a legally sufficient written withdrawal, transfer, or check and that we may treat any such Account Transfer to an Account the same as a deposit, all in accordance with the terms of this Agreement and all of your deposit agreement(s) with us. You agree that we may comply with transfer instructions entered by any person using an authorized User Name and Password, regardless of the restrictions placed at the Account level, i.e., two signatures required or minor no withdrawal. TRANSFER LIMITATIONS Your ability to initiate Account Transfers between deposit Accounts may be limited by federal law or by the terms of your deposit agreements with us. Account Transfers from deposit Accounts that are savings or money market deposit Accounts are limited as required by federal regulation (REG-D). -You agree that we may, without notice or other obligation to you, refuse to make any Account Transfer for security reasons or as otherwise expressly provided in this Agreement or your deposit agreements with us. -No transfers will be allowed through Online Banking if any loan on your WCU Account is past due. -No transfer or debit may exceed the available funds in your account combined with any funds available on a line of credit or any funds available per our overdraft privilege program (if applicable). -The Credit Union may, at its discretion, approve a transaction that takes an account balance negative, which would incur a standard overdraft fee. The Credit Union also reserves the right to refuse a transaction that would result in insufficient funds, draw on unavailable funds, or take an account below a required minimum balance. Electronic withdrawals and/or transfers from a Share/Savings or Money Market Account are limited by Federal regulations to a total of six (6) transfers in any one (1) calendar month. Per Regulation D -If you exceed these limitations, your account may be subject to a fee or be closed. You may make no more than six (6) transfers and withdrawals from your Share or Money Market account to another account of yours or to a third party in any calendar month by means of: Pre-Authorized transfer or withdrawal, Automatic (ACH) transfer or withdrawal, or Internet (WCU Homebanking) transfer, or Mobile (WCU Mobile Apps) transfer, or Telephonic (either WCU Branch or FlashTalk) transfer, or by and automatic overdraft

6 protection transfers (made to cover a check, a draft, a debit card or similar transfer order). In accordance with REGULATION D, WCU allows 6 REG-D transfers in any one calendar month, free. After the 6 th REG-D transfer in any one calendar month, you will be charged a REG-D Overdraft Transfer Fee of $35 per transfer for each additional REG-D transfer. TIME OF ACCOUNT TRANSFERS; POSTING; AND FUNDS AVAILABILITY If you initiate an Account Transfer of available funds between Accounts on or before 6:00 p.m. Central Time ( CT ) on a Business Day, the Account Transfer will be posted on the same Business Day. Account Transfers initiated after 6:00 p.m. CT on a Business Day or on weekends and holidays may be posted on the next Business Day. Account Transfers to make payments to Accounts must be initiated by 6:00 p.m. CT on a Business Day in order to be processed on the same Business Day. Funds transferred will be available for withdrawal on the same Business Day that the Account Transfer is posted by the Credit Union. If there are not available funds in the Account from which a transfer is being made at the time the transfer is processed, at our option, your Account may become overdrawn and you may be charged a fee, or the transfer may be canceled. You authorize us to withdraw the necessary funds from your Account on the date you submit a transfer request. You agree that you will instruct us to make a withdrawal only when a sufficient balance is or will be available in your Accounts. If you do not have a sufficient balance, including available credit under any overdraft protection plan, we may refuse to complete the transaction. In either case, we reserve the right to impose a non-sufficient funds (NSF) fee, and no further attempt will be made by the Credit Union to process the transfer request. The Credit Union is under no obligation to notify you if it does not complete a transfer because there are non-sufficient funds in the Account to process the transaction. In all cases you are responsible for making alternate arrangements. DISRUPTION IN INTERNET BANKING SERVICES You may access our Internet Banking Services 24 hours a day, seven days a week. However, occasionally we may perform regular maintenance and upgrades on systems and equipment, which may result in errors or interrupted service. We cannot guarantee that we will provide notice of such interruptions. Accessibility may also be interrupted because of conditions beyond our control, including, but not limited to, equipment malfunctions, power failures, and, outages in internet or phone service. In no event shall we be liable for any claim arising out of such a delay, interruption, disruption, or similar failure. HARDWARE AND SOFTWARE REQUIREMENTS SYSTEM REQUIREMENTS You need a personal computer or mobile device and access to the Internet to use WCU s Online Banking. You are responsible for installation, maintenance and operation of any required software or hardware. We are not responsible for errors or failures involving any telephone or cable service, Internet service, software or hardware. We cannot provide diagnostic or technical support for your software or hardware. In order to access and retain records in connection with Internet Banking Services, your system must meet the following requirements. General: Broadband Internet Access through your PC or mobile device; An internet browser that supports 128-bit or higher encryption. A personal computer or a mobile phone or device, operating system and telecommunications connections to the Internet capable of supporting the foregoing that meets our system requirements, as may be set out on our website. Updated Operator software on any device used to access Online Banking Sufficient electronic storage capacity on your computer s hard drive or other data storage unit. Sufficient electronic storage capacity on your computer s hard drive or other data storage unit. An account and software capable of reading and responding to your in order to participate in our electronic communications programs. A printer that is capable of printing from your browser and software (in order to print statements, copies of checks, tax documents, etc). Cookies Enabled Pop Ups Allowed Javascript Enabled Acrobat Reader 7.0 (or higher) Operating Systems Windows operating system: Windows 7 and higher Macintosh operating system: Mac OS Yosemite (version and higher) Recommended Web Browsers & Mobile Platforms Desktop Web BROWSERS (The Latest Version of the following):

7 WINDOWS = Chrome, Firefox, Opera, Internet Explorer MAC = Chrome, Firefox, Safari, Opera Mobile Device PLATFORMS (The Latest Version of the following): ANDROID = Chrome and Firefox ios = Chrome, Firefox, Safari Hardware You also confirm that your computer or electronic device meets the specifications and requirements listed below, and permit you to access WCU Homebanking/Mobile Banking and access and retain the disclosures and notices electronically. You are solely responsible for the equipment (including your personal PC and software) you use to access Internet Banking Services. We are not responsible for errors or delays or your inability to access Internet Banking Services caused by your equipment. We are not responsible for the cost of upgrading your equipment to stay current with Internet Banking Services nor are we responsible for any damage to your equipment or the data resident thereon. Internet Connection. You understand and agree that use of or connection to the Internet is inherently insecure and that connection to the Internet provides opportunity for unauthorized access by a third party to your computer systems, networks, and any and all information stored therein. We shall not be responsible for any adverse consequences whatsoever resulting from your connection to or use of the Internet, and shall not be responsible for any use by you of an Internet connection in violation of any law, rule, or regulation or any violation of the intellectual property rights of another. Virus Protection You agree that the Credit Union is not responsible for any electronic virus that you may encounter using Internet Banking Services. Routinely scan your PC using any reliable virus protection product to detect and remove any viruses found. About "Cookies" To provide better service and a more effective web site, we use "cookies" as part of our interaction with your browser. A "cookie" is a small text file placed on your hard drive by our web page server. These cookies do not collect personally identifiable information, and we do not combine information collected through cookies with other personal information to determine who you are or your address. Cookies are commonly used on web sites and do not harm your system. By configuring your preferences or options in your browser, you determine if and how a cookie will be accepted. We use cookies to determine if you have previously visited our web site and for a number of administrative purposes. Changes to hardware or software requirements If our hardware or software requirements change, and that change would create a material risk that you would not be able to access or retain your Electronic Communications, we will give you notice of the revised hardware or software requirements. Continuing to use Electronic Banking Services after receiving notice of the change is reaffirmation of your consent. SECURITY Secure Access to Your Accounts When using our Online Banking application you're protected by several security features including advanced encryption technology to prevent unauthorized access to your accounts. We have taken all appropriate measures to ensure that our website and online banking product is secure, and that our members account information remains private. Our members also play a role in protecting their information. ONLINE BANKING SECURITY When using WCU s Online Banking application you're protected by these security features: Privacy protection of your financial information as detailed in our Privacy Notice (located at wcucu.com) Your session automatically ends when you exit the (Mobile) application. Automatically times out session if you are inactive for a predefined number of minutes (Homebanking). SSL Online Banking uses SSL (secure sockets layer) which ensures that your connection and information are secure from outside inspection. Your online banking User ID and Password should be provided only when your browser shows a Secure Socket Layer (SSL) session is taking place. If your browser doesn t support SSL or 128-bit encryption, you will need to upgrade your browser. Secure Socket Layer (SSL) technology encrypts account information between computers, so that it is virtually impossible to be read by others. We recommend that our members use a current version of browser software so that they may benefit from the most up to date internet security available. After you finish any website session that included viewing or sending private information you should close your browser window. ENCRYPTION: Advanced encryption technology to prevent unauthorized access. Online Banking uses 128-bit encryption to make your

8 information unreadable as it passes over the Internet. MULTIFCATOR AUTHENTICATION Personal security question to further guard against identity theft. You will be required to choose 3 Security Challenge Questions & Answers ( Multifactor Authentication ) prior to completing a successful login to Online Banking for additional security. You will be prompted to answer these questions periodically to validate your identity when using WCU s Homebanking & Mobile Apps. You can change these questions & answers at any time by going to the User Options Tab & choosing Change Challenge Questions. For more information about Multifactor Authentication you may visit RANDOM (CAPTCHA) CODES CAPTCHA stands for Completely Automated Public Turing test to tell Computers and Humans Apart. After your initial login, each time you log in to WCU Homebanking, you will be required to enter a random (CAPTCHA) code (that is case sensitive) on the screen under your User ID as an added security measure. The CAPTCHA process ensures that the person logging into WCU Homebanking is a real live human being as opposed to a computer program attempting to spam the site or user accounts and denies access to anyone who answers incorrectly. USER ID AND PASSWORD A Self-selected username and password is used to confirm your identity and ensure the privacy of each Online Banking session you conduct. Each individual who has access to the Credit Union s Online Banking Services, (Primary Account Owner/Member), must designate a User ID ( User Name ) and a password ( Password ) or call WCU to have login credentials assigned to you. Upon your receipt of your initial Password, you hereby agree to change your Password to a confidential one of your choosing. The system will prompt you to change your Password during your initial sign on. You may change your Password at any time by selecting the USER OPTIONS button located on the main Homebanking (Online Banking) webpage, and then select the CHANGE PASSWORD button. It is recommended that you do not use your Social Security Number, birthday, name, account number, address, or other codes that may be easy for others to determine as your Password. USER ID / USER NAME Must be betweent 5 to 25 characters Must contain at least one letter Contain No symbols PASSWORD Must be 8 to 25 characters Must contain both letters and numbers Contain No symbols except for the underscore _ Passwords are case sensitive Cannot be your SSN or WCU account number or your User ID, or your , NOR any of your 3 previous passwords -Please remember your User ID & Password and keep them secure. Your Online Banking User ID & Password ensures that only you can access your confidential information. -Each User Name for Internet Banking Services must be unique. We will contact you if you choose a User Name that has already been selected and you will be asked to select an alternate User Name. -All Online Banking Services transactions or inquiries must be initiated by use of your User Name and Password. We may accept as authentic any instructions given to us through the use of your Password. -If you enter your password wrong 3 times, your online account will be locked. You will have to call a WCU branch to have your online account unlocked and reset your password. -If you forget your password, you can use the Forgot Password feature or call WCU to have it reset. We will you a temporary password to the address on record with WCU. In order to utilize this feature you will need the following information: a. Last 4 digits of Primary Account Owner/Member's Social Security Number; b. Address on file with WCU; c. Your 5-digit WCU Account Number; and d. The Primary Account Owner/Member's Date of Birth CONFIDENTIALITY OF YOUR PASSWORD No Credit Union employee will ever ask for your Password, nor should you provide it to anyone unless you intend to allow that person access to your Accounts. You agree to keep your Password confidential. If you are contacted by anyone requesting this information, please contact us immediately. Use of the Password by you or by any other person with your authorization will be considered the same as your written signature authorizing us to complete any transaction or request communicated through Internet Banking Services. You agree that any Internet Banking Services transaction or request initiated by use of the Password will be subject to and governed by this Agreement. If you authorize another person to use your Password, that person can use Internet Banking Services to view any information or initiate any transaction on any of the Accounts to the same extent as you, including viewing information or initiating transactions on Accounts to which that person does not otherwise have access. As such, your sharing of your Password is strongly discouraged by the Credit Union, and done

9 at your sole risk and peril. If a third party should gain access to your Password, you alone are responsible for changing the Password so as to deny the third party's access to your banking information. If you permit another person to use Internet Banking Services or give that person your User Name or Password, you are responsible for transfers or advances that person makes from your Accounts even if that person exceeds your authorization. LIABILITY FOR UNAUTHORIZED ACCESS THE CREDIT UNION WILL HAVE NO LIABILITY TO YOU FOR ANY UNAUTHORIZED PAYMENT OR TRANSFER MADE USING YOUR PASSWORD THAT OCCURS BEFORE YOU HAVE NOTIFIED US OF POSSIBLE UNAUTHORIZED USE AND WE HAVE HAD A REASONABLE OPPORTUNITY TO ACT ON THAT NOTICE. You agree to notify us immediately if your Password is lost or stolen or if you believe an unauthorized person has obtained access to your accounts without your permission. You could lose all the money in your account (plus your maximum overdraft line of credit). Telephoning is the best way of keeping your possible losses down. Please call (256) during normal business hours. If any unauthorized use of your Password occurs you agree to (1) cooperate with us and appropriate law enforcement authorities in identifying and prosecuting the perpetrator; and (2) provide assistance requested by us in recovering any unauthorized transfer of funds. If your statement shows transfers that you did not make, tell us at once. If you do not tell us within 60 days after the statement was mailed to you, you may not get back any money you lost after the 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 your statement shows unauthorized Online Banking transfers, notify us at once. Please refer to the last page of your statement for instructions on reporting errors or questions. ONLINE BANKING SECURITY TIPS While we continue to evaluate and implement the latest improvements in Internet security technology, users of the system also have responsibility for the security of their information and should always follow the recommendations listed below. To help enhance your security, we recommend that you follow some general safety guidelines: Use the Logout icon to end an online banking session. This expires all the cookies that were set in your session. The amount of time you can remain inactive before being automatically logged out of online banking can be set under Online Services. For your own security, keep this time setting as short as possible. It is recommended that you balance your account at least once a month so that any discrepancies can be reported to us in a timely manner. -Never leave your computer unattended while logged on to the system. Others may approach your computer and gain access to your account information if you walk away. -Be sure others are not watching you enter information on the keyboard when using the system. -Exit the system when you are finished to properly end your session. Once a session has ended, no further transactions can be processed until you log on to the system again. -Close your browser when you are finished, so that others cannot view any account information displayed on your computer. - Memorize your User ID and Password, it will not expire. - Select a User ID and Password that will be easy for you to remember, but difficult for others to guess. - Do not use names of family members or pets, Social Security number, birthday or other personal information. - Do not use words in a dictionary, slang, or common character sequence such as Choose a User ID and Password that contains at least one lower case and one upper case alphabetic character, at least one number. - For maximum security, use the full available length of your alphanumeric password (always use at least 8 digits) and change it frequently to ensure that the information cannot be guessed or used by others. - Your User ID and Password are case sensitive. - Your User ID and Password cannot be the same. - Your password must be kept confidential. NEVER give or share your User ID and Password with anyone. - Notify us immediately if you believe your User ID and Password have been lost or stolen. -Site best viewed with recent versions of Internet Explorer, Chrome, Firefox and Safari. -Keep your computer free of viruses. Use virus protection software to routinely check for a virus on your computer. Never allow a virus to remain on your computer while accessing the system. When you follow these simple security measures, your financial activities should be secure. MOBILE BANKING SECURITY When using WCU s Mobile Banking application you're protected by these security features: Self-selected username and password to confirm your identity and ensure the privacy of each Mobile Banking session you conduct Privacy protection of your financial information as detailed in our Privacy Notice (located at wcucu.com) Your session automatically ends when you exit the application, and it will automatically time out if you get sidetracked MOBILE BANKING SECURITY TIPS Protect Your Personal Information Use the keypad lock or phone lock function on your mobile device so that no one else can use it or view your information when it's not in use. Keep your device in a secure location when you are not using it to protect

10 it from being stolen or used by an unauthorized party. Do not store sensitive or personal information on your mobile device, such as passwords and account numbers. Use Care Before Downloading Apps Before you download an application on your device, review the privacy policy and understand what specific data the app can access. Download mobile apps only from reputable sources such as your provider's app store to avoid downloading applications with malware and malicious code. Verify that the Site is Secure Be cautious about the sties you visit and the information you release. When banking and shopping on your mobile device, check to be sure the sites are secure. Look for web addresses with https: in the address. This means the site takes extra measures to help secure your information. When in Doubt, Don't Respond Don't open unfamiliar attachments, s, or text messages from unknown sources. Requests for personal information or a call for immediate action are almost always a scam. WCU Credit Union will never ask that you verify any account information over the phone or through . If you receive an or text message purportedly from WCU that you feel is suspicious, please FORWARD that to info@wcucu.com to verify authenticity. TYPES OF MOBILE FRAUD SMS Phishing SMS Phishing is a form of criminal activity via cell phone messages to get you to divulge your personal information, including financial or account information, Social Security number, date of birth, ATM PIN or credit card information, for use in committing fraud or other crimes. A criminal sends you a message that tries to trick you into replying with financial or personal information or clicking on links that will sneak viruses into your mobile device. Don't respond to a text message that requests personal or financial information. WCU will never ask you to provide your information in this way. Lost and Stolen Devices Mobile phones and tablet devices offer convenience, but they're also easy to lose or steal, which can put your information at risk. Here are some ways you can protect yourself if your device is lost or stolen: Password-protect your device so it can't be accessed unless the password is entered Enable your keypad lock or phone lock function on your device to lock the device when its not in use Consider using a remote wipe program that gives you the ability to remotely delete all data on your device Keep a record of the devices make, model, phone number, and serial number in case it's stolen Mobile Malware Mobile malware is malicious software that is installed on your device with the intent to steal your personal information or financial details. One of the main ways that the malware can access your phone is through the Wi-Fi networks and Bluetooth. Only use secure and trusted Wi-Fi networks and keep Bluetooth switched off when you aren't using it. If your device supports security and anti-virus software, consider installing that software. Backup the device's data and keep the copy in a safe and secure location. ACKNOWLEDGEMENT OF COMMERCIALLY REASONABLE SECURITY PROCEDURES By using Internet Banking Services, you acknowledge and agree that this Agreement sets forth security procedures for electronic banking transactions, which are commercially reasonable. You agree to be bound by instructions, whether authorized or unauthorized, which we implement in compliance with these procedures, unless you have given us prior notice of possible unauthorized use (and we had a reasonable opportunity to act on such notice). DISCLOSURE OF DEPOSIT ACCOUNT INFORMATION TO THIRD PARTIES We are strongly committed to protecting your security and confidentiality. You are assured that we will guard your information from third parties except for the following situations: -When it is necessary to complete a transfer as requested by you or investigate or resolve a problem. -In order to verify the existence and condition of your Account for a third party, such as a credit bureau when you have authorized the disbursement of such information. -In order to comply with laws, government agency rules or orders, court orders, subpoenas or other legal processes. -If you give us your written permission. For more information on the Credit Union s privacy policies contact: WCU Credit Union, Attn: Compliance Officer, 2505 Hwy 31 South, Decatur, AL 35603, Phone (256) ELECTRONIC MAIL SERVICE ( ) We will not accept electronic mail ( ) instructions from you for stop payments, notice of unauthorized use or other specific instructions regarding your Accounts. We may not immediately receive, read or process an that you send to us. If you need to contact us immediately to stop payment, to report an unauthorized use of your Password, to report unauthorized access to an Account, or for any other reason, you must call us at (256) We will not be responsible for acting on or responding to any request. Regular non-encrypted internet is not secure. In the instances where we have provided our addresses, they are provided for information inquiries of a non-confidential nature. You should not include personal or confidential information in any transmission to us. We, in turn, will not include any confidential account information in any response. You may alternatively contact us by telephone, U.S. Mail or by visiting our office. The Credit Union s service is not located on a secured encrypted server and others can view the information you enter. Sending electronic messages to us through regular is also not protected by a high level of encryption. Electronic mail may be used to send you notices, disclosures and other information required by regulations. We may send this information to you by posting it on our Web Site or by . We may also send it to you by regular postal mail in writing at the address shown in our records. If you have given us an address or postal address, we are entitled to rely on that address and

11 assume that messages sent to that address are received by you, until you give us notice in writing that the address is no longer valid. You agree that information we post to our Web Site or send by or regular postal mail will be deemed delivered at the time it is posted or sent. Information you send to us is deemed delivered when we receive and review it. We preserve the content of your address and our response so that we can more efficiently handle any follow-up questions you may have. We also do this to meet legal and regulatory requirements. If we think that a particular account or service might apply to your situation, we may occasionally contact you at your address to inform you of potential benefits and availability. If we send you a notice, disclosure or other message electronically and you wish to print it and are unable to do so, contact us at (256) and we will provide you with a paper copy. FEES AND CHARGES Access to Internet Banking Services is currently available at no additional charge to you. The Credit Union reserves the right to charge for access at a later date and you will be notified in advance if this happens. Check images are available through Internet Banking Services for free. There may be other costs and charges associated with your Accounts as stated in your Account agreement(s) such as stop payment charges. ERRORS AND ADJUSTMENTS We agree to correct any error made in crediting or debiting any Account by making the appropriate adjustment to the applicable Account. You agree to repay promptly any amount credited to your Account in error, and you authorize us to initiate a debit transfer from any of your Accounts to obtain payment of any erroneous credit. ACCOUNT RECONCILIATION The Account statements or other notices provided to you by us will notify you of (a) the execution of transfers and the debits and/or credits to the Accounts made with respect to such transactions, and (b) amounts debited by the Credit Union from your Accounts for payment of the services or other charges pursuant to this Agreement. You agree that we will not be required to provide any other notice to you of the execution of transfers or debits. You agree to promptly examine each statement for an Account and to promptly report any discrepancies between your records and the Account statements or any other notices mailed by the Credit Union to you. SETTLEMENT OF OBLIGATIONS To the fullest extent permitted by applicable law, you authorize us to obtain payment of your obligations to us under this Agreement from time to time by (a) initiating debits to any of the Accounts or (b) deducting the payment from the amount of any Account Transfer. Such obligations include, without limitation, fees owed to us, and settlement for Account Transfers initiated through our Internet Banking Services. At the time any Account is closed or Internet Banking Services are terminated, you agree that all such obligations will be immediately due and payable to us, and you authorize us to withhold the amount of any such obligations from any Account. Debiting an Account or deducting payment from the amount of any Account Transfer is not the Credit Union's exclusive remedy under this or any other section of this Agreement, and the Credit Union will not be deemed to have made an election of remedies by making any such debit or deduction on any one or more occasions. LIMITS ON THE CREDIT UNION S LIABILITY If we do not complete an Account Transfer to or from your Account on time or in the correct amount, we might be liable for some of your losses or damages. However, there are some exceptions. We will not be liable for instance if: Through no fault of ours, your Account does not have enough money to make the transfer. The transfer would exceed the balance in the Account you use for overdraft protection, or the credit limit on your overdraft checking line of credit, or the line has been closed. Your computer, the Web Site, phone lines, or the Credit Union s computer systems were not working properly or were temporarily unavailable, and this problem should have been apparent to you when you attempted the transfer. The money in your Account is subject to legal process or other encumbrances restricting transfer. Circumstances beyond our control prevented the transfer, despite reasonable precautions that we have taken. Such circumstances include telecommunication outages, viruses, system failure, fires, floods, and other natural disasters. We have placed a hold on funds in your Account or remitted funds to another party with your knowledge, pursuant to reasonable business procedures, or in compliance with legal process such as garnishment, tax levy, court order, etc. We have received incomplete or inaccurate information from you or a third party involving the Account or transfer. We have a reasonable basis for believing that unauthorized use of your User Name, Password, or Account has occurred or may be occurring. You or we have terminated this Agreement or closed the Account. You do not completely and properly follow the terms of this Agreement or instructions provided regarding how to make the transfer. Your funds are being held or frozen or are subject to legal proceedings. The funds in your Account are unavailable (funds are only conditionally credited until they become available for withdrawal). UNDER NO CIRCUMSTANCES ARE WE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, PUNITIVE OR EXEMPLARY DAMAGES, INCLUDING LOST PROFITS, COSTS AND ATTORNEYS FEES, EVEN IF INFORMED OF THEIR POSSIBILITY, ARISING IN ANY WAY OUT OF THE USE OF INTERNET BANKING SERVICES. THIS LIMITATION OF LIABILITY SHALL NOT BE CONSTRUED AS AN ATTEMPT TO WAIVE OR LIMIT ANY REMEDY THAT IS IDENTIFIED AS NOT BEING SUBJECT TO WAIVER BY AGREEMENT IN ANY ALABAMA OR FEDERAL CONSUMER PROTECTION LAW OR REGULATION. Our liability for Electronic Fund Transfers made to or from Accounts is also governed by other Sections of this Agreement. If any provision herein is inconsistent with any provision of other Sections or any provision of applicable law that cannot be

12 varied or waived by agreement, the provisions of those Sections or applicable law shall control. To the fullest extent permitted by applicable law, you agree that we will have no liability whatsoever for any loss, damage, or claim arising out of any delay or failure in the performance of Internet Banking Services in accordance with the terms of this Agreement, including but not limited to, that resulting from our negligence. Our duties and responsibilities to you are strictly limited to those described in this Agreement, except with respect to any provisions of the law applying to Electronic Fund Transfers that cannot be varied or waived by agreement. You acknowledge that we may subcontract a portion of the Internet Banking Services to be provided under this Agreement. The Service Provider is an independent contractor and not the Credit Union's agent. The Credit Union s sole duty shall be to exercise reasonable care in the initial selection of the Service Provider. You acknowledge that no express or implied warranty, including, without limitation, any warranty of merchantability or fitness or a particular purpose, is made by the Credit Union with respect to Internet Banking Services or the software, and the Credit Union hereby disclaims all such warranties. To the fullest extent permitted by applicable law, and without limiting the generality of the foregoing, the Credit Union shall not be liable at any time to you or any other person for any loss, charge, fee, penalty, expense or other damage resulting from any failure or delay of the performance of the Credit Union's responsibilities under this Agreement which is caused or occasioned by any act or thing beyond the Credit Union's reasonable control, including, without limitation, legal restraint, interruption of transmission or communication facilities, virus, equipment failure, electrical or computer failure, war, emergency conditions, natural disasters, fire, storm, or other catastrophe, or inability to obtain or delay in obtaining wire services or Internet access, or refusal or delay by the Service Provider or another financial institution to execute any transfer. In addition, the Credit Union shall be excused from any failure or delay in executing a transfer, if such execution would result in the violation of any applicable state or federal law, rule, regulation or guideline. To the fullest extent permitted by applicable law, you agree that the Credit Union shall not have any liability whatsoever for any loss caused by the act, error, or omission of you or any other person, including, without limitation, the Service Provider any Internet access service provider, any Federal Reserve Bank or transmission or communications facility or any intermediary or receiving financial institution, and no such person shall be deemed the Credit Union's agent. We are not obligated to conduct any transaction or instruction which does not comply with the terms and conditions of the Eligible Accounts. We may also refuse to honor any transaction we have reason to believe may not be authorized by you or any other party whose authorization may be necessary to effect the transaction. Nor will we honor any transaction, including that which involves funds subject to hold, dispute, or other restriction or legal process that we believe prevents their withdrawal or transfer. We will not honor any transaction or instruction that is in violation of any law, regulation, or Credit Union policy, procedure or practice. We will not honor any transaction or instruction that we have reasonable cause not to honor. YOUR LIABILITY FOR UNAUTHORIZED OR ERRONEOUS TRANSFERS To the fullest extent permitted by applicable law, you agree to be responsible for all unauthorized or erroneous transactions initiated through Internet Banking Services. You have the obligation to immediately notify the Credit Union if your Password has been lost or stolen, or if someone has transferred funds from your Account through Internet Banking Services without your permission (or is contemplating doing so). The following provisions of this Section apply only to your liability for unauthorized Electronic Fund Transfers. Liability for Account Transfers excluded from Regulation E coverage shall be governed by the terms and conditions of your account you have with us. An "unauthorized Electronic Fund Transfer" means an Electronic Fund Transfer from an Account that is initiated by another person without your authority to initiate the Electronic Fund Transfer and from which you receive no benefit. The term does not include any Internet Banking Services Electronic Fund Transfer that is initiated by a person to whom you furnished your Password, unless you have notified us that Electronic Fund Transfers by that person are no longer authorized and we have had reasonable opportunity to act on that notification. We may require that the notice be in writing. If you notify us verbally, we may require you send us your complaint or question in writing. When you contact us, please provide the following information (1) your name (2) the date and dollar amount of the transaction in question (3) the transaction number if available, or a description of the transaction. You could lose all the money in your Account, some or all of the money in any linked Account, or any other funds you have with us that we permitted by law to use as a set off, or up to your maximum overdraft line of credit (if applicable), if you fail or refuse to immediately advise the Credit Union of the unauthorized use of your Password. If your statement shows Electronic Fund Transfers that you did not make, tell us at once. If you do not tell us within sixty (60) calendar days after we mail or make available to you the FIRST statement on which the problem or error appeared, you shall not be entitled to assert a claim against the Credit Union, nor be entitled to any damages from the Credit Union, for unauthorized transfers made after the sixty (60) days if we can prove that we could have prevented such transaction had you reported it to us within the sixty (60) calendar days. This sixty (60) day limitation is without regard to the standard of care exercised by the Credit Union. If you believe your Password has been lost or stolen or that someone has transferred or may transfer money from an Account without your permission, call: (256) , Or write: WCU Credit Union 2505 Hwy 31 South, AL USER RISKS WCU Credit Union Online Banking (Including Mobile Apps.) acts solely as an operator of the Services for your convenience and use of the Services, and any reliance by you upon any content or information available to you through the Services (the Materials ), including any action taken by you because of such use or reliance, is at your sole risk. Neither WCU Credit Union Online Banking (Including Mobile Apps.) nor any of its affiliates, third-party providers, partners, licensors, employees, distributors or agents is responsible or liable for, or makes any representations or warranties as to the

13 following, without limitation: - Any representations, promises, recommendations or inducements that may be made by or through any party (including vendors) found at, on, through or from the Services; -The timeliness, accuracy, reliability, completeness, legality, copyright compliance or decency of the Services or any Materials; -Any inaccuracy, omission, error or delay in the Services or any Materials; Non-performance of or interruption to the Services or any Materials due to, without limitation: (i) any act or omission by any disseminating party, (ii) any force majeure or any other cause beyond the control of any disseminating party, or (iii) outages, transmission quality or malfunctions of telephone circuits or computer systems, including any defects or failures with respect to your software, computer systems or Internet access provider; -The quality of the Services or any Materials (including the results to be obtained from use of them); or -Any loss resulting from, including any unauthorized access by a third party, arising out of or related to your access and/or use of or interaction with the Services or the Materials. LOSS OF DATA You agree that, should your data be lost or destroyed as a result of your systems failure or interruption, you are responsible for all consequences resulting from such systems failure or interruption. You are responsible for verifying the accuracy and completeness of all transactions conducted through the Program including those affected by any system failure or interruption. HYPERLINKS LINKS TO OTHER WEBSITES DISPLAYED ON THE WEB SITE ARE OFFERED FOR INFORMATIONAL PURPOSES ONLY. THE CREDIT UNION IS NOT RESPONSIBLE FOR AND DOES NOT CONTROL THE CONTENT OF SUCH THIRD-PARTY SITES. THE CREDIT UNION DOES NOT GUARANTEE THE AUTHENTICITY OF DOCUMENTS AT SUCH SITES, NOR DOES IT ENDORSE THE IDEAS, OPINIONS, INFORMATION, PRODUCTS OR SERVICES OFFERED AT SUCH SITES. THE CREDIT UNION DISCLAIMS LIABILITY FOR ANY FAILURE OF PRODUCTS OR SERVICES ADVERTISED ON SUCH SITES. EACH SUCH SITE MAY HAVE A PRIVACY POLICY, WHICH IS DIFFERENT FROM THE CREDIT UNION S, AND MAY PROVIDE LESS SECURITY. USE OF HYPERLINKS IS AT THE MEMBER S OWN RISK. In no event shall WCU Credit Union be responsible or liable for any information, content, products, services, practices or other materials on or available from or through such sites. GOVERNING LAW, OTHER AGREEMENTS; SEVERABILITY The terms and conditions of this Agreement are cumulative with and in addition to any terms of the Credit Union s signature cards or Membership and Account Agreement for your Account(s), the applicable Account disclosures, the Fee Schedule, the Schedule of Funds Availability, the Credit Union s Electronic Fund Transfer Agreement and Disclosure Statement, all as may be amended from time to time. In the event of any conflict between this Agreement or the term of any related materials regarding the Credit Union's obligations to you, the terms of this Agreement will control. If any provision of this Agreement is unlawful or unenforceable, each such provision or writing will be without force and effect without thereby affecting any other provision hereof. No consumer protection provision of the Federal Electronic Fund Transfer Act or Federal Reserve Board Regulation E is intended to be waived by you under this Agreement unless law permits the waiver. The parties agree to be bound by the operating rules and guidelines of the National Automated Clearing House Association and the applicable local Automated Clearing House Association as in effect from time to time with respect to all automated clearing house transfers made hereunder. This Agreement will be governed by the substantive laws of the United States, applicable federal regulations, and to the extent not inconsistent therewith, the laws of the State of Alabama. Your use of the Internet Banking Services may also be affected by the agreements between us for your deposit, credit card, and other linked Accounts. When you link an Account to Internet Banking Services, you do not change the agreements you already have with us for that Account. For example, when you use Internet Banking Services to access a credit Account, you do so under the terms and conditions we gave you in the agreement and disclosure for the credit Account. You should review those agreements for any applicable fees, for limitations on the number of transactions you can make, and for other restrictions, which might impact your use of an Account with Internet Banking Services. ASSIGNMENT OR WAIVERS You may not assign all or any part of your rights or duties under this Agreement. No waiver of the terms of this Agreement will be effective, unless in writing and signed by an authorized officer of the Credit Union. NO THIRD-PARTY BENEFICIARIES This Agreement is for your benefit and is not intended to grant, and shall not be construed as granting, any rights to or otherwise benefiting any other person, except as expressly otherwise provided in this Agreement. OWNERSHIP OF MATERIALS/ PROPRIETARY RIGHTS You are permitted to use content delivered to you through the Services only in connection with the Services. You acknowledge and agree that WCU Credit Union Online Banking (Including Mobile Apps.) and/or its licensors or suppliers own all rights to the Site and the Services, the content displayed on the Site and the Services including its look and feel (e.g., text, graphics, images, logos and button icons), photos, editorial content, notices, and other Intellectual Property Rights, made

14 available to you as a part of or in conjunction with the Services. You are only permitted to use any of the foregoing as expressly authorized by these Terms. WCU Credit Union Online Banking (Including Mobile Apps.), and all other names, logos, icons and marks identifying WCU Credit Union Online Banking s (Including Mobile Apps.) products and services are WCU Credit Union Online Banking s (Including Mobile Apps.) trademarks and may not be used without our prior written consent. You may not remove or alter any trademark, logo, copyright or other proprietary notices, legends, symbols or labels on any portion of the Services. The content and information on our Web Site is the property of the Credit Union. It should not be duplicated. By accessing Internet Banking Services, you hereby acknowledge that you will be entering the Web Site, which may be used only for authorized purposes. The Credit Union may monitor and audit usage of the system, and all persons are hereby notified that use of Internet Banking Services constitutes consent to such monitoring and auditing. Unauthorized attempts to up-load information and/or change information on the Web Site are strictly prohibited. ENTIRE AGREEMENT This Agreement supplements any other agreements or disclosures related to your account(s), including the Deposit Account Agreement and Disclosures. If there is a conflict between this Agreement and any others, or any statements made by employees or agents, this agreement shall supersede. EXCLUSIVE AGREEMENT You agree that these Terms are the complete and exclusive agreement between you and WCU Credit Union Online Banking (Including Mobile Apps.). These Terms supersede any proposal or prior agreement, oral or written, and any other communications between you and WCU Credit Union Online Banking (Including Mobile Apps.) relating to the subject matter of these Terms. These Terms, as the same may be amended from time to time, will prevail over any subsequent oral communications between you and WCU Credit Union Online Banking (Including Mobile Apps.). AMENDMENTS AND CHANGES TO THIS AGREEMENT We may amend this Agreement in whole or part from time to time within 30 days written notification prior to the change taking effect. Each amendment will be effected by our mailing or otherwise delivering the amendment, revised Agreement and/or notice thereof to you in accordance with applicable federal and state laws. If you do not agree with the change(s), you must notify us in writing prior to the effective date to cancel your access. To the extent permitted by applicable law, amendments or changes to term(s) or condition(s) may be made without prior notice or obligation to you if: (a) if the Service Provider changes any term without providing us sufficient notice to enable us to properly notify you; (b) for security reasons; (c) to comply with applicable law; (d)does not result in higher fees, (e)more restrictive service use, (f)or increased liability to you, or (g) as otherwise expressly provided in this Agreement. We reserve the right to waive any terms of this Agreement. Any such waiver shall not affect our right to future enforcement. MISCELLANEOUS You agree and acknowledge that if you breach these Terms, WCU Credit Union Online Banking (Including Mobile Apps.) may have no adequate remedy at law and will suffer irreparable harm as a result of such a breach and will therefore be entitled to injunctive relief without the obligation of posting a bond. The titles and headings of these Terms are for convenience and ease of reference only and shall not be utilized in any way to construe or interpret the agreement of the parties as otherwise set forth herein. Each covenant and agreement in these Terms shall be construed for all purposes to be a separate and independent covenant or agreement. If a court of competent jurisdiction holds any provision (or portion of a provision) of these Terms to be illegal, invalid, or otherwise unenforceable, the remaining provisions (or portions of provisions) of these Terms shall not be affected thereby and shall be found to be valid and enforceable to the fullest extent permitted by Law. All covenants, agreements, representations and disclaimers as to warranties and limitations on liability made in these Terms shall survive your acceptance of these Terms and the termination of these Terms. WCU Credit Union Online Banking (Including Mobile Apps.) may modify these Terms, at any time and without notice to you, by delivering such amended terms to the address you provide to WCU Credit Union Online Banking (Including Mobile Apps.) at the time of registration or that you subsequently updated, or by posting updated Terms on the Site. You manifest your acceptance of such amended terms if you continue to use or access the Services after such amended terms have been delivered to you by or posted. If you do not agree with such amended terms, your only remedy is to discontinue your use of and access to the Services pursuant to these Terms. Otherwise, these Terms may not be amended except in writing signed by WCU Credit Union Online Banking (Including Mobile Apps.) and you. For all purposes of these Terms, except as otherwise expressly provided or unless the context otherwise requires: (i) the terms defined herein include the plural as well as the singular and vice-versa; (ii) all headings are for convenience only and shall not affect the interpretation or construction of these Terms; and (iii) the words including, included and includes mean inclusion without limitation. CHILDREN'S ONLINE PRIVACY (COPPA) The Children s Online Privacy Protection Act regulates the online collection of information from minors under 13 years of age. If you are a parent or guardian sponsoring a child under 13 years of age for membership, you are consenting to the online collection of your child s information. If you decide at a later date that you are opposed to this collection of online information, simply let us know and we will close the minor s account. This Children's Online Privacy disclosure is provided in compliance with the Children's Online Privacy Protection Act (16 CFR Part 312). This disclosure is specifically directed to parents and guardians of minors under 13 years of age. We recognize our obligation to keep member information secure and confidential, especially for children under the age of 13. This obligation is very important to us. The guidelines below describe our continued commitment to protect the personal and financial information of our members and website users under age 13. We reserve the right to make changes to our privacy

15 guidelines whenever warranted to further protect our young members' personal and financial information. Internet Browsers and Online IDs We have taken all appropriate measures to ensure that our website and home banking product is secure and that our young members' personal and account information remains private. Our young and adult members also play a role in protecting their credit union account information. Your (and their) online banking Account ID and Password should be provided only when your (or their) browser shows a Secure Socket Layer (SSL) session is taking place. Secure Socket Layers (SSL) encode (scramble) account information between computers, so that it is virtually impossible to be read by others. We recommend that all our members, young and adult, use a current version of browser software so that they may benefit from the most up to date Internet security available. After you or your child finish any website session that includes viewing or sending private information you (or they) should close the browser window. Computer Cookies A cookie is a small text file placed on your hard drive by a web server. Cookies are commonly used on websites and do not harm your computer system. We use cookies to provide a more interactive and helpful website, and to customize the information you see. You can control how a cookie will be handled (accepted or rejected) on your computer by configuring your preferences or options in your browser software. We use cookies for administration purposes of our website. We never combine information collected through a cookie to you or to gain confidential account information. Collecting and Using Young-Member Information For our internal use, we collect the following information about children under 13 as we do for adults: Information we receive from you or the child on applications and other forms, such as name, address, social security number, assets and income; and Information about the child's transactions with us, such as account balances, deposits and withdrawals, parties to transactions and credit card usage; and Information we receive from consumer reporting agencies, such as credit worthiness and credit history (if applicable). Any information we collect is used to service our member accounts and to help us learn more about the financial products or services they would be interested in. Collecting information from our website helps us provide better products and services. We do gather and analyze data regarding usage of our website, including domain name, number of page hits, pages visited, length of user session, time of day, day of week, etc., to evaluate and improve our website. As provided by law, we are prohibited from collecting more information than is reasonably necessary for the purposes stated in this Children's Online Privacy Policy. In addition, you as the child's parent or guardian can review the child's information we have collected, have us delete it and/or refuse to permit further collection or use of the child's information. To do so, contact us by any of the methods shown at the end of this Children's Online Privacy Policy. Please understand that if you have us delete all information on your child, we will be unable to continue to maintain or service your child's account and the account will have to be closed. We restrict access to protected information to those employees who need to know that information to provide products or services to the minor. We also maintain physical, electronic and procedural safeguards that comply with federal standards to protect the child's information. If the child chooses to close their account(s) with us or becomes an inactive member, we will continue to adhere to the privacy policies and practices described in this statement. Website Calculating and/or Planning Tools To help our members with financial decisions, various planning or calculating tools are provided on our website. We do not capture the personal information the child may provide on these planning tools. Links from Our Website We cannot control the content of other internet sites. Links from our website are intended to serve as a benefit to our members and are offered on an as is basis. We are not responsible for accuracy, security or content of site links. We encourage our members to view privacy and security disclosures on all websites they visit. Address Collection In order to serve the young member better we may ask her or him to provide us with an address. address information is necessary to manage our account database. We assure you that the address the child submits won't be sold or shared with any other party outside the credit union unless we are compelled to do so by law. On occasion we may contact the child at the address they've provided, if we have product or service information to share that may be of potential benefit. Sending and Receiving Messages When the child s us, we safeguard the content of the , address and our response, so that we can more efficiently handle any follow-up questions you may have. We also do this to meet any legal and/or regulatory requirements. is outside our Secure Socket Layer (SSL) and therefore we recommend our members do not send confidential information via . One Nevada's response back to the sender will not include confidential account information. Sharing or Selling Account Information To assist us in offering services to members, we may at times choose to share information with companies that work for us, or as otherwise permitted or required by law. These companies might, for example, assist us in how best to offer members, including young members, certain products or services. If information is shared, these companies act on our behalf and are obligated to keep the information that we provide to them confidential. We do not sell personal account information. Please review our Privacy Notice (PDF) for details about information sharing at WCU Credit Union. If you want to limit your sharing contact us: By telephone: (256) By mail: WCU Credit Union, 2505 Hwy 31 South, Decatur, AL Member Surveys Finding out what our members' needs are and checking on how we're doing in fulfilling those needs, is very important to us. At times we will ask that the young member complete a mail-in or online survey. All surveys and the information the child might provide are optional. We use the information gathered to improve our products and services. Never do we sell or disclose survey information to companies not working for us. Online Applications All of our online applications are transmitted to us using Secure Socket Layer (SSL) technology. When you and your child use an online application to apply for a loan, information may be shared with a credit bureau before a loan

16 decision can be made. Contacting us About the Child's Account Keeping account information accurate and up to date is very important. We will make corrections to account information as quickly as possible. If you ever find that information regarding the child's account is inaccurate or not current, please let us know. We use various ways to offer services and products to our members, including young members. The child can choose not to receive offers made by mail, telephone or , and you may choose for us to not share your child's personal or account information. Whatever the preferences of you and/or your child, we will respect that request. You have the option to consent to the collection and use of your child's personal information without consenting to the disclosure of that information to third parties. Please let us know if you would like further information on how, what or why we collect and use information from minors under age 13. To contact us you can use any of the following methods: Visit your nearby branch Call our Member Service Center Send us an Write to: WCU Credit Union, 2505 Hwy 31 South, Decatur, AL ILLEGAL USE You agree not to use Online Banking for any illegal, fraudulent, unauthorized or improper manner or purpose and will only be used in compliance with all applicable laws, rules and regulations, including all applicable state, federal, and international Internet, data, telecommunications, telemarketing, spam, and import/export laws and regulations. You agree that you will not attempt to: (i) access this service for which your use has not been authorized; (ii) use or attempt to use a third party s account; or (iii) otherwise abuse the service. We will use commercially reasonable efforts to secure the service to prevent access by unauthorized persons and to prevent the introduction of any unauthorized tracking or malicious code, such as a computer virus or spyware. However, no security system is failsafe, and despite our efforts the security of the service could be compromised or malicious code could be introduced by third parties. We will provide you with notice if your information is the subject of a security breach as required by applicable law. INDEMNIFICATION You agree, at your expense, to defend, indemnify, hold harmless, protect and fully compensate WCU Credit Union Online Banking (Including Mobile Apps.), its affiliates, and their respective officers, directors, employees, consultants, agents, distributors, partners, licensors and third-party providers from any and all claims, liability, damages, losses, expenses and costs (including attorneys fees) caused by or arising from (a) a third-party claim, action or allegation of infringement based on your use of the Service or information, data, files or other content you submitted or uploaded; (b) any fraud, manipulation, or other violation of Law by you; (c) a breach of these Terms by you; (d) your acts or omissions; or (e) any third-party claim, action or allegation brought against WCU Credit Union Online Banking (Including Mobile Apps.) arising out of or relating to a dispute between its users over the terms and conditions of a contract or related to the purchase and sale of any services. For the avoidance of doubt, if you are a business entity, your obligations hereunder shall extend to indemnification based on the acts and omissions of your employees, consultants and agents. NO WAIVER WCU Credit Union Online Banking (Including Mobile Apps.) shall not be deemed to have waived any of its rights or remedies hereunder unless such waiver is in writing and signed by WCU Credit Union Online Banking (Including Mobile Apps.). No delay or omission on the part of WCU Credit Union Online Banking (Including Mobile Apps.) in exercising any rights or remedies shall operate as a waiver of such rights or remedies or any other rights or remedies. A waiver on any one occasion shall not be construed as a waiver of any rights or remedies on future occasions. CHOICE OF LAW AND FORUM FOR DISPUTES By visiting or using the Site and/or the Services, you agree that the laws of the State of Alabama, without regard to principles of conflict of laws, will govern these Terms. To the extent that these Terms conflict with applicable state or federal law, such state or federal law shall replace such conflicting terms only to the extent required by Law. You agree that any claim or dispute of any sort that might arise between you and WCU Credit Union Online Banking (Including Mobile Apps.), its officers, directors, employees, agents or affiliates must be brought in Morgan County, Alabama, subject to applicable jurisdictional requirements in any such action or proceeding. You irrevocably waive any objection to such venue. You understand that, in return for your agreement to this provision, WCU Credit Union Online Banking (Including Mobile Apps.) is able to offer the Services as these Terms designate and that your assent to this provision is an indispensable consideration to these Terms. You also acknowledge and agree that, with respect to any dispute with WCU Credit Union Online Banking (Including Mobile Apps.), its officers, directors, employees, agents or affiliates, arising out of or relating to your use of the Services or these Terms: (i) YOU ARE GIVING UP YOUR RIGHT TO HAVE A TRIAL BY JURY; and (ii) YOU ARE GIVING UP YOUR RIGHT TO SERVE AS A REPRESENTATIVE, AS A PRIVATE ATTORNEY GENERAL, OR IN ANY OTHER REPRESENTATIVE CAPACITY, OR TO PARTICIPATE AS A MEMBER OF A CLASS OF CLAIMANTS, IN ANY LAWSUIT INVOLVING SUCH DISPUTE. Contact Information: WCU Credit Union, 2505 Hwy 31 South, Decatur, AL 35603, support@wcucu.com.

17 TERMINATION OF ONLINE BANKING SERVICES You may cancel Online Banking Services and this Agreement at any time. In the event you wish to discontinue using Online Banking Services, contact the Credit Union in writing. We reserve the right to terminate your use of Online Banking Services at any time with or without prior written notice and for any reason. We may terminate your use of Online Banking if you or any authorized user of your account/password breaches this or any other agreement with us; or if we have reason to believe there has been unauthorized use of your account or password. However, termination of the system will not affect the rights and responsibilities of the parties under this Agreement for transactions initiated before termination. This cancellation applies to your Online Banking Services and does not terminate your other Credit Union Accounts. CONSENT TO ONLINE BANKING AGREEMENT / SIGNATURES You agree that you are the only individual authorized to use Online Banking Services under this Agreement through the use of your User Name/User ID and Password. You agree to all of the provisions of this agreement (to the extent applicable as provided in this agreement) by any and all of the following means: Using WCU Online Banking service to perform any transactions. Physically signing this agreement. Causing your company representative to physically sign this agreement, if you are a business entity. Completing a separate electronic consent form to receive disclosures and enter into this agreement electronically. Your electronic consent or use of WCU Online Banking service has the same effect as if you had signed this agreement with your physical signature or that of your authorized company representative. Your physical signature, electronic consent, or use of WCU Online Banking service is also your acknowledgement that you have received a copy of this agreement in paper form, or if you have provided a separate electronic consent, in electronic form. If you are offered or provided an electronic copy of this agreement but would like to have a paper copy, please contact us at or write to us at WCU Credit Union, 2505 Hwy 31 South, Decatur, AL and we will forward a paper copy to you. ACCOUNTS TAB WCU Online Banking Option Screens 1. SUMMARY The Accounts SUMMARY tab will show you a general overview of your account. Get up-to-the-minute account balances, loan balances and account histories on the account summary page, and view payment and transaction history. Insured Accounts Summary Insured Accounts Summary section displays a general overview of your insured accounts, including the account title, type, balance and available balance. Insured accounts include: Savings Money markets Share certificates Checking Individual retirement accounts To view the details of an insured account, click on the account title. Your current transaction activity will then be displayed. You may also view more of your account history by going to the Next History Date Range, selecting dates using the fields provided and clicking More History. If you are looking at the details of your checking account, you can view a copy of the check by clicking on the check number. - Obtain balance info for share, share draft, loan, money market, club, IRA and certificate accounts. - Review transaction history (including pending transactions) for share, share draft, loan, money market, club, IRA and certificate accounts. - Transfer funds to & from share, share draft, and Money Market accounts (including cross/linked WCU Accounts). - Schedule one-time or recurring transfers in the future (including cross-account transfers).

18 - Make loan payments from your share, share draft, and Money Market accounts. - Determine if a particular item has cleared. - View, print and download images of recently paid checks drawn on your Accounts. - Verify the last date and amount of your payroll deposit. - Submit address changes. - View, print, save, or download account history or *account statements, or *tax documents. (*Available only to members who have signed up & agreed to terms/conditions for E-Statements through WCU Homebanking.) - Direct us to make payments from your Account to 3 rd parties (optional with a draft account, under separate Bill Pay agreement) Pending Transactions and Deposits View pending transactions to your checking account. A pending transaction is a type of hold on your account that affects your available balance. Your account balance can often differ from your available balance due to a pending transaction or hold on your account. For example, gas stations often hold up to $75 or more from your account when you fill up even though your final transaction amount may only be $30. That gas station transaction will eventually clear your account for $30 but they hold the funds from your available balance until the transaction clears. Regularly viewing your pending transactions may help you avoid unexpected overdraft fees. Loan Summary The Loan Summary section displays a general overview of your loans, including the loan type, balance, available balance, rate, payment and the due date. To view the details of your loan, click on the loan title name. Your current transaction activity will then be displayed. You may also view your loan account history by going to the Next History Date Range, selecting dates using the fields provided and clicking More History. Cleared Check Copies To print a copy of a cleared check: 1. Log into WCU s Homebanking and search your account history to find the check number you are looking for. 2. Click on the Check # under description to view the check 3. Click on the box at the bottom of the screen Print Check Export Account Information The Export option allows you to download your financial history to your computer in CSV (Comma Separated Values) format. To export your transaction history: 1. Click on the Accounts tab. 2. Select the account you d like to export history for. 3. Select the date range. 4. Click on Get History 5. Click on Export History To Choose csv Click on the Export sub-tab. 5. Click on open or save to Download Data to your computer. 2. TRANSFER You may use our Online Banking Services to initiate Account Transfers between your WCU Accounts. All of your Online Banking transactions are secure and you receive a transfer confirmation number for your records. The completion of a transfer is subject to the availability of sufficient funds in the account you are transferring from. If you do not have sufficient funds, the transaction will not be completed. No transfer will be completed in Online Banking if your account has a loan that is past due. To Transfer funds: 1. Click on Accounts tab. 2. Click on the Transfer sub-tab. 3. Enter the amount you d like to transfer in the field provided. Do not include dollar signs or commas. 4. Select the account you would like to transfer from (only eligible accounts will appear). 5. Select the account you would like to transfer to (only eligible accounts will appear). If you are transferring funds to a different member number (cross/linked account), their eligible accounts will be displayed next to their member number. 6. Click on Transfer Funds. Cross Account / Linked Account Transfers When you first set up your User Name/User ID & Password, we will link all of your eligible WCU Accounts. If you have a cross account (linked account you are joint owner on), you may also transfer funds to and from that account.

19 In order to become joint on an account, you must do so at a branch. Once you are joint on the account, it will be added to your Online Banking. If you open an additional eligible account/suffix at a later date, we will link your new account to the Online Banking Service. 3. SCHEDULED TRANSFERS You can schedule a transfer to occur at a certain date and time in the future. You can set up the transfer to happen once, or on a reoccurring basis. To view or modify the scheduled transfers that you have set up for your account, click the Accounts tab and select Scheduled Transfers. To Add a new scheduled transfer: 1. Click the Accounts tab and select Scheduled Transfers. 2. Click Create New Scheduled Transfer link and follow the instructions. To view the scheduled transfers for the current month: 1. Click the Accounts tab and select Scheduled Transfers. 2. Click on View Current Schedule To view the next or previous months transfers 1. Click the Accounts tab and select Scheduled Transfers. 2. Click the Prev Month or Next Month links To view a list of all scheduled transfers ordered by the next transfer date: 1. Click the Accounts tab and select Scheduled Transfers. 2. Click on View by Next Transfer Date To edit or delete a scheduled transfer 1. Click the Accounts tab and select Scheduled Transfers 2. Click on View Edit Current schedule 3. Click on the description of the transfer (highlighted in blue) 4. Select the edit or delete option 4. E-STATEMENTS Your monthly account statement can be viewed online! At the touch of your fingertips and in a secure environment, you have access to your monthly account statements. Plus you save both time and money by receiving your statement electronically instead of by mail. By choosing to view your statement online, you help us save paper, postage and other natural resource To sign-up for E-Statements 7. Login to WCU Homebanking 8. Click on the Accounts tab 9. Click on estatements. 10. Verify your address on the screen 11. Read the disclosure/agreement 12. Click on I Consent at the bottom of the estatement Signup page to consent to accept statements electronically instead of by way of US mail. To view or print your estatement 4. Log into WCU Homebanking by entering your User ID and Password 5. Click the Accounts Tab 6. Select the estatement option 7. Click on monthly statements 8. Click on which month you want to view 9. Click on the word pdf on the screen & wait for the file to load 10. Your electronic statement will open in a new window. 11. Click on the printer icon 12. Click on print -Once you have set up your WCU Online Banking account, you will receive a monthly notification that your account statement is ready for you to view, print, or download securely from our website. -In order to continue to receive estatements, you must keep your address updated with WCU at all times. -If you are unable to view the estatement page by the next day, please contact WCU Credit Union.oth estatements and check images are displayed in Adobe Acrobat Reader, so you must have this application installed. -If you do not currently have Adobe Acrobat Reader, you can download a copy free by going to BILL PAY TAB Included in the Online Banking Services is an optional service that allows you to direct us to make payments from your eligible deposit Account to a person or entity to which you wish a bill payment to be directed or is a person or entity from which you receive electronic bills, as the case may be. Our free Bill Pay system works just like an online checkbook. You control what bills are paid, payment date, and amount paid. Set up one time or recurring payments, expedite payments, send money online to another person, or edit payments as needed nothing comes out of your account until you say so. This is provided through

20 our service entitled Bill Pay. This service is provided by us through our non-affiliate service providers. Any applicable fees may apply for the use of Bill Pay as provided in the separate Bill Payment Service Agreement which controls the Bill Pay service. Standard delivery of bills is free. Expedited options will incur charges. Transaction limits may apply. BILLPAY INITIAL SETUP Step 1 - Sign into WCU s Homebanking and select the Bill Pay tab. Step 1 - Accept the terms and conditions of the Bill Payment Service Agreement. Subsequently you will be able to activate Bill Pay Services. If you do not choose the Bill Pay service at this time, you may add the service later through the Online Banking Services. At the present time, you may use Bill Pay to: - Initiate bill payments through our Bill Pay service -See WCU s BillPay Agreement & Disclosure online at for full details. - There is no limit on the number of bill payments per day. - See Section 2 of WCU s EFT Agreement/Disclosure for transfer limitations that may apply to these transactions. We will process bill payment transfer requests only to those creditors the Credit Union has designated in the User Instructions and such creditors as you authorize and for whom the Credit Union has the proper vendor code number. We will not process any bill payment transfer if the required transaction information is incomplete. We will withdraw the designated funds from your share draft account for bill payment transfer by the designated cut-off time on the date you schedule for payment. We will process your bill payment transfer within a designated number of days before the date you are scheduled for payment. You must allow sufficient time for vendors to process your payment after they receive a transfer from us. Please leave as much time as though you were sending your payment by mail. -We cannot guarantee the time that any payment will be credited to your account by the vendor. USER OPTIONS TAB Online Banking can be customized to fit your needs. You can decide how long the system stays connected before it logs you out, create personalized account nicknames and set your account history date range. For security, you will be required to change your Password and User ID upon initial registration Please remember your User ID & Password and keep them secure. Your Online Banking User ID & Password ensures that only you can access your confidential information. Change your Password: 1. Click on the User Options link. 2. Click on Change Password. 3. Enter your current password in the Old Password field. 4. Enter a new password in the New Password field. 5. Re-enter the new password in the Re-enter password field. 6. Click Submit and you will receive a confirmation that your password has been updated. Remember, passwords are case-sensitive! Must be 8 to 25 characters Must contain both letters and numbers No symbols except for the underscore _ CANNOT BE your SSN or WCU account number or your User ID, or your , NOR any of your 3 previous passwords -You may change your home banking password at any time. -For security purposes, it is recommended you change your password every six months. -For security, you will be required to change your Password and User ID upon initial registration -IMPORTANT: We do not have access to your password. -Please remember your User ID & Password and keep them secure. -Your Online Banking User ID & Password ensures that only you can access your confidential information. -In the case of a forgotten password, please use our password reset tool or contact us to reset your password. Change User Name/User ID You may change your User Name/User ID at anytime. 1. Click on the User Options link. 2. Click on Change User ID. 3. Enter your NEW User Name/User ID in the box where your current User Name is shown. 4. Click on Change User Name and the screen will say it has been updated. Must be between 5 to 25 characters Must contain at least 1 letter Must contain NO symbols

21 Change Address This online form allows you to view/update your address. Your address will be used for E-Statement and notifications and to provide you with product or service information that may be a potential benefit. Please refer to our Privacy Policy for more information. To change your address: 1. Click on the User Options link. 2. Click on Change Address. 3. Enter your updated address in the field provided. 4. Click Submit and you will receive a confirmation that your address has been updated. Change Your Challenge Questions The Change Your Challenge Questions feature allows you to change your challenge questions. Use the security code section if you want to receive a security code to your mobile phone/ instead of being challenged by the security questions. This feature will be available only in Online Banking. For Mobile Banking you will still be challenged with your questions. To change your Challenge Question: 1. Click on the User Options link. 2. Click on Change Your Challenge Quesitons. 3. Select the 3 Questions and 3 Answers you want form the drop-down menus. 4. Click on submit to save your changes. Change History Date Range The Change History Date Range allows you to select what account history dates you would like to have displayed. By default, only the current month s history is displayed. To change your history date range: 1. Click on the User Options link. 2. Click on Change History Date Range. 3. Select a date range by selecting one of the date range descriptions. 4. Click on Change Date Range to save your changes. Change Your Timeout The Change Your Timeout feature allows you to set the number of minutes of inactivity in your online banking session before the system automatically logs you out. To change your timeout: 1. Click on the User Options link. 2. Click on Change Your Timeout. 3. Select the number of minutes from the drop-down menu. 4. Click on Change Timeout to save your changes. Create Account Nickname Personalize the account names that are displayed in home banking for easier recognition. To create or update an account nickname: 1. Click on the User Options link. 2. Click on Create Account Nickname. 3. Modify your account nickname in the field provided to the right of the account name. Please do not use punctuation or special characters when creating nickname 4. Click on Submit to save your changes. 5. To restore the system default name, delete the nickname from the provided field and click on Submit to save your changes. Change Security Key Choose a word that displays on login for your user security key. This will help you know that the website is valid. To create or update a security key: 1. Click on User Options link. 2. Click on Change Security Key 3. Modify your key 4. Click on Submit to save your changes Mobile Banking If you prefer to use your phone s web browser, you can use WCU s Mobile Apps to access your WCU Account information. WCU Mobile Banking is free to members who use Online Banking. MOBILE BANKING INITIAL SETUP You must be set up to use WCU Homebanking and have logged in at least once in order to access WCU s Mobile Banking / Mobile Apps.

22 If you are NOT currently a WCU Homebanking User, please see the ONLINE BANKING INITIAL SETUP Section above for instructions on how to register for WCU Homebanking. Step 1 Register and Log In as a WCU Homebanking User Step 2 Go to the itunes Store or Google Play Store, search and download the WCU Mobile app for Android, iphone or ipad Step 3 Use your WCU Homebanking Login Credentials for your Login Credentials for WCU s Mobile Apps Step 3 The Check the address on file for the Primary Account Owner for a security code. The first time you Login to Mobile App, an with a security code will be sent to the primary address on file. Step 3 Enter this code in the app as requested. Once the code has been verified the app setup is complete. If you remove WCU s Mobile App from your device, you will be required to do this again if you re-install WCU s Mobile App). Remember Mobile App Account History available for viewing is limited to the past 90 days. Contact Us Our Member Service Contact Center is open Monday through Friday 8am -5pm and Saturday, 8am- 12pm and can assist you with Online Banking or credit union account questions. s sent during closed hours will be answered on the next business day. Unless this Agreement provides otherwise, you can communicate with us in any one of the following ways: at: memberservice@wcucu.com; s sent during closed hours will be answered on the next business day. Telephone at: (256) ; Postal Mail at: 2505 Hwy 31 South, Decatur, AL 35603; Office at: MAIN OFFICE Hwy 31 South, Decatur, AL 35603; MOULTON BRANCH Franklin Smith Rd, Moulton, AL Common Error Messages The following errors may occur when accessing Online Banking: Account verification error. Your password is incorrect. Verify the password and re-enter it. Check to make sure the Caps Lock is not on. Passwords are case-sensitive; the Caps Lock may alter the way your password is being entered. The account has been locked. You have had too many invalid login attempts. As a security measure, Online Banking will allow three invalid password attempts and will lock out the account on the fourth try. To reset your password, please use our password reset tool or contact us for assistance. We re sorry, we are unable to process your request at this time. Online Banking is temporarily down for system maintenance. Try again periodically. If the message is displayed repeatedly, contact us. Troubleshooting Error Messages To show us the exact error message that you are receiving, display the error message on your screen then press Print Screen on your computer s keyboard. This will transfer the image to your clipboard which can then be pasted into a Word document or other application. When experiencing an error message, try the following steps before contacting your financial institution: 1. Clear the cache, reload, or refresh. 2. Close the browser. 3. Retry. After trying this and you still continue to receive the error message, contact us. IMPORTANT: When reporting problems to us, please have as much information ready as possible (e.g. when the problem occurred, browser version, etc.). WCU Credit Union estatement Disclosure: Electronic Delivery of Statements and Notices: By submitting your request for estatements electronically, you consent and agree that WCU Credit Union ( Credit Union ) may provide certain disclosures and notices to you in electronic form, in lieu of paper form. Scope of Consent for electronic delivery of statements: Your consent to receive electronic statements covers the periodic statements you are provided in connection with your share and loan accounts (except credit cards) with the Credit Union. Your consent also covers all disclosures that are required or may be provided on or with your account and/or loan statements, including, but not limited, to the Billing Rights Statement required by the Truth in Lending Act and the Error Resolution Notice required by the Electronic Fund Transfer Act. You understand that the Credit Union will discontinue mailing printed loan and share account statements to your address of record. All future statements will be maintained on a website which you access to obtain, review, print, and copy/download your periodic statements. You may access your statement via WCU Homebanking using the procedures we authorize. Scope of Consent for electronic delivery of notices: Your consent to receive electronic notices covers any notice or other type of communication provided to you pursuant to the terms of this Agreement. These notices will be sent via to the last known address provided by you. You agree to notify us promptly of any change of your address. If you consent to electronic

23 statements, tax forms, and disclosures, it will be your responsibility to check your for notices of statement, tax form, or disclosure availability. WCU Credit Union estatement Procedures: On the first business day of each month your statement (not all accounts generate monthly statements) will be available for viewing, printing, or downloading. To view your estatement, visit and log into your WCU Homebanking account. After signing into your online account; click on the Accounts button in the navigation bar and in the drop down menu select estatements, WCU s estatement Disclosure (Terms and Conditions) will appear on the screen. After reading disclosure/terms & conditions, & agreeing to same, click on the I Consent button. The Monthly Statements button will appear on the screen, click on the Monthly Statements button, and a list of your available statements will appear. To view your statement, click on the month you wish to review. To print a statement, click on the word PDF on the screen & wait for the image to generate, then click on the printer icon and print all pages you require. Statements can also be downloaded in PDF format. Duty to Review Periodic Statements: You must promptly access/review your estatement and any accompanying items and notify us in writing within sixty (60) days of the first transmittal of a periodic statement of any error, unauthorized transaction, or other irregularity. The sixty (60) days begins on the date your statement became available. If reported orally, we require written confirmation within ten (10) days. If you allow someone else to access your statement, you are still fully responsible to review the statement for any errors, unauthorized transactions, or other irregularities. Any applicable time periods within which you must notify us of any errors on your account statement(s) shall begin on the Date regardless of when you receive and/or open the estatement. We will investigate your concern and will correct any error promptly. If we take more than 10 business days to do this, we will credit your account for the amount you think is in error so you will have use of the money during the time it takes us to complete our investigation. Change of address: You agree to notify us immediately of any change in your address. Notice must be either: in person; by fax (256) ; by phone (256) ; in writing to WCU Credit Union at 2505 Hwy 31 South, Decatur, AL 35603; or updating directly through WCU s online banking Security: Although your online statement is secure, you understand the importance of your role in preventing misuse of your accounts and you agree to promptly examine your estatement for each of your Credit Union accounts as soon as you access it. You agree to protect the confidentiality of your account and account number, and your personal identification information, as well as your driver s license number and social security number. You understand that personal identification information by itself or together with information related to your account, may allow unauthorized access to your account. Data transferred via estatement is not encrypted. You acknowledge that the Internet is inherently insecure and that all data transfers, including electronic mail, occur openly on the Internet and potentially can be monitored and read by others. We cannot and do not warrant that all data transfers utilizing the Internet, or transmitted to and from us, will not be monitored or read by others. The Credit Union s efforts to secure electronic banking does not secure the internet or the transaction of information over the internet. The Credit Union does not provide protection for transfers or data transfers utilizing your personal computer, laptop, tablet, or mobile device. The Credit Union shall not be liable for any loss, harm, or fraud resulting from the introduction of a computer virus, worm or other malicious code in your computer access device. The Credit Union will never contact you on an unsolicited basis to request information concerning your electronic credentials, including your User ID, Password, or Security Questions. If anyone contacts you and requests this information, contact us immediately. You are responsible for keeping your log-in password confidential. The Credit Union recommends its consumer and business members perform a risk assessment and review its electronic/online account controls and passwords periodically. The Credit Union recommends you periodically review your online account access practices to ensure security, including: Who has access to your online accounts?; How and where are your user names and passwords stored?; and How strong are your passwords and how often are they changed? If you are suspicious of any account activity or experience a member information security related event or believe that your User ID or Password, or Security Questions have been lost, or stolen, please contact The Credit Union at (256) immediately. Password Security: For security reasons, we require that you log-in to WCU Homebanking to access your estatements. If you incorrectly enter your WCU Homebanking password three times you will be prevented from access. Should this happen, contact us at during business hours for us to unlock your account. Your log-in password is confidential information that should be known only by you. The Credit Union will not, for any reason, ask you for your log-in password. If anyone contacts you and requests this information, contact us immediately. You are responsible for keeping your log-in password confidential. Change in Terms: We may change any term of this Agreement at any time. If you do not wish to accept the change, you may terminate this Agreement by withdrawing your consent to receive statements and notices electronically.

24 Right to Withdraw Consent: You have the right to withdraw your consent to have your statements, tax forms, and disclosures provided in an electronic form by notifying the Credit Union in person; by fax (256) ; by phone (256) ; or in writing to WCU Credit Union at 2505 Hwy 31 South, Decatur, AL We must receive your withdrawal of consent by the 25 th of the month for you to receive a paper statement for that statement period. You will receive paper statements for subsequent statement periods. You may obtain a paper copy of any statement, tax form, or disclosure on request, even if you choose to receive statements and notices electronically. Requests for paper copies of a statement can be made in person; by phone (256) ; or in writing to WCU Credit Union at 2505 Hwy 31 South, Decatur, AL There may be a fee for statement copies. Please refer to the Fees Schedule. Disclaimer of Warranty and Limitation of Liability: We make no warranty of any kind, express or implied, including any implied warranty of merchantability or fitness for a particular purpose, in connection with the estatements provided to you under this Agreement. We do not and cannot warrant that estatements will operate without error, or that estatements will be available at all times. Except as specifically provided in this Agreement, or otherwise required by law, you agree that our officers, directors, employees, agents or contractors are not liable for any indirect, incidental, special or consequential damages under or by reason of any services or products provided under this Agreement or by reason of your use of estatements, including loss of profits, revenue, data or use by you or any third party, whether in an action in contract or tort or based on a warranty or any other legal theory. Joint Accounts: If your share account is joint with another person, one of you may consent to receive notices, statements, tax forms, and disclosures electronically and that person s election to receive estatements shall apply to both of you. We will then send the notice regarding the availability of your estatements, tax forms, and disclosures to the address provided in lieu of providing a paper statement. Our Right to Terminate: You agree that we can terminate our estatements service and revert to printed mailed statements for any reason at any time. Communications between Credit Union and You: Unless this Agreement provides otherwise, you can communicate with us in any one of the following ways: at: memberservice@wcucu.com; Telephone at: (256) ; Postal Mail at: 2505 Hwy 31 South, Decatur, AL 35603; Office at: MAIN OFFICE Hwy 31 South, Decatur, AL 35603; MOULTON BRANCH Franklin Smith Rd, Moulton, AL Hardware and Software Requirements: GENERAL REQUIREMENTS: Broadband Internet access, A browser that supports encryption, Enabled Cookies, Enabled Javascript, Pop Ups allowed. BROWSERS: For accessing the Internet we recommend that you use either Microsoft Internet Explorer 6.0 or higher or Firefox. REQUIRED OPERATING SYSTEMS: Windows operating system: Windows 7 and higher; Macintosh operating system: Mac OS Yosemite version and higher. If you are reading this agreement online, you have the necessary hardware and software to access your estatements. To open and view an estatement or any other document sent by the Credit Union your computer system must be equipped with Adobe Acrobat software version 6.0 or higher. You may download Adobe Acrobat for free at or by clicking on the link provided on the estatement page. To retain a copy of your statements, you will need a printer attached to your computer capable of printing Web pages. To save your statements on your computer you can use the Save feature of your Internet software to save the pages to your hard drive or to some other media, such as a cd or flash drive. Additional Terms and Conditions of Your Electronic Statement Agreement: The terms and conditions of your Membership and Account Agreement for each of your Credit Union accounts as well as your other agreements with the Credit Union such as loans continue to apply not withstanding anything to the contrary in this Agreement. WCU Credit Union Bill Pay Agreement & Disclosure: ******THIS IS A FREE SERVICE TO ALL MEMBERS OF THE CREDIT UNION****** THIS IS YOUR BILL PAYING AGREEMENT WITH WCU CREDIT UNION. YOU MAY USE WCU CREDIT UNION BILL PAYING SERVICE, BILL PAY, TO DIRECT WCU CREDIT UNION TO MAKE PAYMENTS FROM YOUR DESIGNATED CHECKING ACCOUNT TO THE PAYEES YOU CHOOSE IN ACCORDANCE WITH THIS AGREEMENT. THE TERMS AND CONDITIONS OF THIS AGREEMENT ARE IN ADDITION TO THE ACCOUNT AGREEMENTS, DISCLOSURES AND OTHER DOCUMENTS IN EFFECT FROM TIME TO TIME GOVERNING YOUR ACCOUNT (THE ACCOUNT RULES).

25 "YOU" OR "YOUR" MEANS EACH PERSON WHO IS AUTHORIZED TO USE THE SERVICE. "PAYEE" MEANS ANYONE, INCLUDING THE FINANCIAL INSTITUTION, YOU DESIGNATE AND THE FINANCIAL INSTITUTION ACCEPTS AS A PAYEE. HOW TO SET UP PAYEES/PAYMENTS: IF YOU WANT TO ADD A NEW PAYEE, USE "SET UP PAYEE" ON THE HOMEBANKING/BILLPAY SITE OR SPEAK TO A SERVICE REPRESENTATIVE. YOU MAY ADD A NEW FIXED PAYMENT TO A PAYEE, ONLY IF THE PAYEE IS ON YOUR AUTHORIZED LIST OF PAYEES, AND BY ACCESSING THE SERVICE, AND ENTERING THE APPROPRIATE INFORMATION. MOST OTHER ADDITIONS, DELETIONS, OR CHANGES CAN BE MADE BY USING THE HOMEBANKING/BILLPAY SERVICE ONLINE. THE FINANCIAL INSTITUTION RESERVES THE RIGHT TO REFUSE THE DESIGNATION OF A PAYEE FOR ANY REASON. EACH PAYEE ACCEPTED BY THE FINANCIAL INSTITUTION WILL BE ASSIGNED A PAYEE CODE. YOU MAY PAY ALMOST ANY PAYEE YOU WISH. THERE ARE SEVERAL RESTRICTIONS: 1) THE MERCHANT MUST BE LOCATED IN THE UNITED STATES; 2) PAYMENTS MAY NOT BE REMITTED TO TAX AUTHORITIES OR GOVERNMENT AND/OR COLLECTION AGENCIES; 3) PAYMENTS MAY NOT BE REMITTED TO SECURITY COMPANIES SUCH AS AMERITRADE FOR STOCK PURCHASES OR TRADE TAXING AUTHORITIES AND 4) COURT DIRECTED PAYMENTS ARE UNAUTHORIZED (ALIMONY, CHILD SUPPORT, OR OTHER LEGAL DEBTS). DON'T FORGET YOU CAN USE THIS SYSTEM TO: - SEND PAYMENTS TO YOUR SON/DAUGHTER IN COLLEGE, - PAY YOUR LOCAL ORTHODONTIST, - PAY YOUR CREDIT CARDS, - PAY YOUR CHARITABLE DONATIONS, ETC. A MERCHANT IS DEFINED AS ANYBODY (COMPANY OR INDIVIDUAL) TO WHOM YOU WANT TO SEND MONEY. THE FINANCIAL INSTITUTION IS NOT RESPONSIBLE IF A BILL PAYMENT CAN NOT BE MADE DUE TO INCOMPLETE, INCORRECT, OR OUTDATED INFORMATION PROVIDED BY YOU REGARDING A PAYEE OR IF YOU ATTEMPT TO PAY A PAYEE THAT IS NOT ON YOUR AUTHORIZED PAYEE LIST. THE FINANCIAL INSTITUTION WILL PROCESS VARIABLE PAYMENTS ON THE BUSINESS DAY (GENERALLY MONDAY THROUGH FRIDAY, EXCEPT HOLIDAYS) YOU DESIGNATE THE BILL IS TO BE PROCESSED, PROVIDED THE PAYMENT REQUEST IS RECEIVED PRIOR TO THE CUT-OFF TIME SET BY THE FINANCIAL INSTITUTION, WHICH IS CURRENTLY 4:00 PM, EASTERN STANDARD TIME. VARIABLE BILL REQUESTS RECEIVED AFTER THE BUSINESS DAY CUT OFF TIME, OR AT ANY TIME ON A NON-BUSINESS DAY WILL BE PROCESSED ON THE NEXT BUSINESS DAY. THE FINANCIAL INSTITUTION RESERVES ITS RIGHT TO CHANGE THE CUT-OFF TIME BY GIVING YOU NOTICE IF IT CHANGES. FOR RECURRING PAYMENT REQUESTS: IF YOU DESIGNATE A PROCESSING DATE OF THE 28TH THROUGH THE 31ST OF A MONTH AND THIS DATE FALLS IN A SHORT MONTH, PROCESSING WILL BE INITIATED ON THE FIRST BUSINESS CALENDAR DAY OF THE MONTH FOLLOWING THAT DATE. OTHERWISE, RECURRING PAYMENT REQUESTS WILL BE PROCESSED ON THE DATES YOU HAVE DESIGNATED, UNLESS SUCH DATE FALLS ON A NON-BUSINESS DAY RESULTING IN YOUR PAYMENT BEING PROCESSED ON THE NEXT BUSINESS DAY. YOU MUST ALLOW A MINIMUM OF FIVE (5) BUSINESS DAYS, PRIOR TO THE DUE DATE, FOR EACH BILL PAYMENT (RECURRING OR VARIABLE) TO REACH THE PAYEE. IT IS THE RESPONSIBILITY OF THE SUBSCRIBER TO SCHEDULE/ACTIVATE RECURRING PAYMENTS. IT IS OUR RECOMMENDATION THAT ADDITIONAL DAYS BE ALLOWED FOR PAYMENTS TRAVELING MORE THAN 4 STATES AWAY. YOU AGREE TO HAVE AVAILABLE AND COLLECTED FUNDS ON DEPOSIT IN THE ACCOUNT YOU DESIGNATE IN AMOUNTS SUFFICIENT TO PAY FOR ALL BILL PAYMENTS REQUESTED, AS WELL AS, ANY OTHER PAYMENT OBLIGATIONS YOU HAVE TO THE FINANCIAL INSTITUTION. THE FINANCIAL INSTITUTION RESERVES THE RIGHT, WITHOUT LIABILITY, TO REJECT OR REVERSE A BILL PAYMENT IF YOU FAIL TO COMPLY WITH THIS REQUIREMENT OR ANY OTHER TERMS OF THIS AGREEMENT. IF YOU DO NOT HAVE SUFFICIENT FUNDS IN THE ACCOUNT AND THE FINANCIAL INSTITUTION HAS NOT EXERCISED ITS RIGHT TO REVERSE OR REJECT A BILL PAYMENT, YOU AGREE TO PAY FOR SUCH PAYMENT OBLIGATIONS ON DEMAND. YOU FURTHER AGREE THE FINANCIAL INSTITUTION, AT ITS OPTION, MAY CHARGE ANY OF YOUR ACCOUNTS WITH THE FINANCIAL INSTITUTION TO COVER SUCH PAYMENT OBLIGATIONS. ANY BILL PAYMENT CAN BE CHANGED OR CANCELED, PROVIDED YOU ACCESS THE SERVICE PRIOR TO THE CUT-OFF TIME ON THE BUSINESS DAY PRIOR TO THE BUSINESS DAY THE BILL PAYMENT IS GOING TO BE INITIATED. LIABILITY: YOU ARE SOLELY RESPONSIBLE FOR CONTROLLING THE SAFEKEEPING OF AND ACCESS TO YOUR HOMEBANKING/BILLPAY LOGIN INFORMATION. YOU ARE LIABLE FOR ALL TRANSACTIONS YOU MAKE OR THAT YOU AUTHORIZE ANOTHER PERSON TO MAKE EVEN IF THAT PERSON EXCEEDS HIS OR HER AUTHORITY. YOU WILL BE RESPONSIBLE FOR ANY BILL PAYMENT REQUEST YOU MAKE THAT CONTAINS AN ERROR OR IS A DUPLICATE OF ANOTHER BILL PAYMENT. THE FINANCIAL INSTITUTION IS NOT RESPONSIBLE FOR A BILL PAYMENT THAT IS NOT MADE IF YOU DID NOT PROPERLY FOLLOW THE INSTRUCTIONS FOR MAKING A BILL PAYMENT. THE FINANCIAL INSTITUTION IS NOT LIABLE FOR ANY FAILURE TO MAKE A BILL PAYMENT IF YOU FAIL TO PROMPTLY NOTIFY THE FINANCIAL INSTITUTION AFTER YOU LEARN THAT YOU HAVE NOT RECEIVED CREDIT FROM A PAYEE FOR A BILL PAYMENT. THE FINANCIAL INSTITUTION IS NOT RESPONSIBLE FOR YOUR ACTS OR OMISSIONS OR THOSE OF ANY OTHER PERSON, INCLUDING, WITHOUT LIMITATION, ANY TRANSMISSION OR COMMUNICATIONS FACILITY, AND NO SUCH PARTY SHALL BE DEEMED TO BE THE FINANCIAL INSTITUTION'S AGENT. IN ANY EVENT, THE FINANCIAL INSTITUTION WILL NOT

26 BE LIABLE FOR ANY SPECIAL, CONSEQUENTIAL, INCIDENTAL, OR PUNITIVE LOSSES, DAMAGES, OR EXPENSES IN CONNECTION WITH THIS AGREEMENT OR THE SERVICE, EVEN IF THE FINANCIAL INSTITUTION HAS KNOWLEDGE OF THE POSSIBILITY OF THEM. THE FINANCIAL INSTITUTION IS NOT LIABLE FOR ANY ACT, FAILURE TO ACT OR DELAY IN ACTING IF IT IS CAUSED, IN WHOLE OR IN PART, BY ANY CAUSE BEYOND THE FINANCIAL INSTITUTION'S REASONABLE CONTROL. AMENDMENT AND TERMINATION THE FINANCIAL INSTITUTION HAS THE RIGHT TO CHANGE THIS AGREEMENT AT ANY TIME BY NOTICE MAILED TO YOU AT THE LAST ADDRESS SHOWN FOR THE ACCOUNT ON THE FINANCIAL INSTITUTION'S RECORDS, BY POSTING NOTICE IN BRANCHES OF THE FINANCIAL INSTITUTION, OR AS OTHERWISE PERMITTED BY LAW. THE FINANCIAL INSTITUTION HAS THE RIGHT TO TERMINATE THIS AGREEMENT AT ANY TIME. YOU MAY TERMINATE THIS AGREEMENT BY WRITTEN NOTICE TO THE FINANCIAL INSTITUTION. THE FINANCIAL INSTITUTION IS NOT RESPONSIBLE FOR ANY FIXED PAYMENT MADE BEFORE THE FINANCIAL INSTITUTION HAS A REASONABLE OPPORTUNITY TO ACT ON YOUR TERMINATION NOTICE. YOU REMAIN OBLIGATED FOR ANY PAYMENTS MADE BY THE FINANCIAL INSTITUTION ON YOUR BEHALF. FEES: THE FEE FOR THE BILL PAYING SERVICE IS = FREE FOR AN UNLIMITED NUMBER OF MONTHLY PAYMENTS. ADDITIONAL CHARGES FOR CUSTOMER REQUESTED SERVICES AND OTHER ITEMS: THESE CHARGES WILL ONLY BE ASSESSED IF YOU REQUEST ONE OR MORE OF THE SERVICES LISTED HERE. THERE WILL BE NO CHARGE FOR ANY ITEM IF NEEDED TO CORRECT A FINANCIAL INSTITUTION ERROR. WRITTEN CORRESPONDENCE TO PAYEE...$10.00 PER PROOF OF PAYMENT NOT NECESSITATED BY A DISPUTE...$10.00 PAYMENTS RETURNED DUE TO CUSTOMER ERROR...$5.00 COPY OF BILLPAY CHECK...$20.00 OVER DRAFT FEE (PER ITEM)...$35.00 THE FINANCIAL INSTITUTION RESERVES THE RIGHT TO CHARGE YOU FOR RESEARCH TIME INVOLVING PAYMENTS NO LONGER AVAILABLE IN YOUR SCREEN HISTORY. YOU WILL BE INFORMED OF ANY SUCH CHARGES BEFORE THEY ARE INCURRED. BILL PAYMENTS ARE PROCESSED BY ELECTRONIC FUND TRANSFERS (EFT). PLEASE SEE THE ELECTRONIC FUND TRANSFERS DISCLOSURE STATEMENT INCLUDED, OR, RECEIVED WHEN YOU OPENED YOUR ACCOUNT, WHICH DISCLOSES IMPORTANT INFORMATION CONCERNING YOUR RIGHTS AND OBLIGATIONS. WCU Credit Union Electronic Funds Transfer Agreement & Disclosure (Reg-E): This Electronic Fund Transfers Agreement and Disclosure is the contract which covers your and our rights and responsibilities concerning the electronic funds transfer (EFT) services offered to you by Wolverine Credit Union ( Credit Union ). In this agreement, the words you and "yours" mean those who sign the application or account card as applicants, joint owners, or any authorized users. The words we," us, and our" mean the Credit Union, The word account means any one (1) or more share and share draft accounts you have with the Credit Union. Electronic funds transfers are electronically initiated transfers of money from your account through the EFT services described below. By signing an application or account card for EFT services, signing your card, or using any service, each of you, jointly and severally, agree to the terms and conditions in this agreement and any amendments for the EFT services offered. 1. EFT SERVICES - If approved, you may conduct any one (1) or more of the EFT services offered by the Credit Union. a. Debit Card. if approved you may use your card to purchase goods and services from participating merchants. If you wish to pay for goods or services over the Internet, you may be required to provide card number security information before you will be permitted to complete the transaction. You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. Funds to cover your card purchases will be deducted from your share draft account. For everyday debit card transactions (including one-time debit transactions) and ATM transactions: you must consent to the Credit Union s overdraft protection plan in order for the transaction amount to be covered under the plan. Without your consent, the Credit Union may not authorize and pay an overdraft resulting from these types of transaction. Services and fees for overdrafts are shown in the document the Credit Union uses to capture the member s opt-in choice for overdraft protection (Reg-E Consent Form What you need to know about Overdrafts & Overdraft Fees). No transfer or debit may exceed the available funds in your account combined with any funds available on a line of credit or any funds available per our overdraft privilege program if applicable. For other types of transactions, if the balance in your account is not sufficient to pay the transaction amount, the Credit Union may pay the amount and treat the transaction as a request to transfer funds from other deposit accounts, approved overdraft protection accounts, or loan accounts that you have established with the Credit Union. If you initiate a transaction that overdraws your account, you agree to make immediate payment of any overdrafts together with any service charges to the Credit Union. In the event of repeated overdrafts, the Credit Union may terminate all services under this Agreement. You may use your card and personal identification number (PIN) in ATMs of the Credit Union, networks, and such other

27 machines or facilities as the Credit Union may designate. At the present time, you may also use your card to: - Withdraw funds from your share, share draft, and Money Market accounts. - Transfer funds from your share, share draft, and Money Market accounts. - Obtain balance Information for your share, share draft, and Money Market accounts. - Make point-of-sale (POS) transactions with your card and personal identification number (PIN) to purchase goods or services at merchants that accept Visa. - Order goods or services by mail or telephone from places that accept Visa. LIMITATIONS ON TRANSACTIONS The following limitations on the frequency and amount of Debit Card transactions may apply: - There is no limit on the number of Debit Card purchases you make per day. - Purchase amounts are limited to the amount in your account. - There is no limit to the number of cash withdrawals you may make in any one (1) day from an ATM machine. - You may withdraw up to a maximum of $ in any one (1) day from an ATM machine, if there are sufficient funds in your account. - There is no limit on the number of POS transactions you may make in any one (1) day. - For security purposes, there are other limits on the frequency and amount of transfers available at ATMs. - You may transfer up to the available balance in your accounts at the time of the transfer. -The Credit Union may set other limits on the amount of any transaction, and you will be notified of those limits. -The Credit Union may, at its discretion, approve a transaction that takes an account balance negative, which would incur a standard overdraft fee. -The Credit Union reserves the right to refuse any transaction which would draw upon insufficient funds, exceed a credit limit, lower an account below a required balance, or otherwise require us to Increase our required reserve on the account. The Credit Union may suspend your debit card if you incur overdrafts in excess of the available balance in your account, including any Overdraft Privilege limit. Debit cards on your account will remain suspended until you make sufficient deposits so that your available balance, taking into account any Overdraft Privilege limit, is positive and then you contact us. if your account is overdrawn more than thirty-two (32) consecutive calendar days. Debit cards on your account will remain suspended until you make sufficient deposits so that your account balance is positive. if we are unable to contact you due to an incorrect mailing address or phone number(s). You must contact us with your correct mailing address and/or phone number(s) to have your debit card reinstated. If your debit card is suspended, you will be unable to use your debit card for purchases or to access your account at the ATM, and if you use your debit card for recurring payments, e.g., utilities, you are responsible to make other arrangements for your recurring debit payment(s). - See Section 2 for transfer limitations that may apply to these transactions. b. FLASH TALK. If we approve FLASH TALK for your accounts, a separate personal identification number (PIN) will be assigned to you. You must use your personal Identification number EPIN) along with your account number to access your accounts. At the present time, you may use FLASH TALK to: - Withdraw funds from your share, share draft, and Money Market accounts. - Transfer funds from your share, share draft, and Money Market accounts. - Obtain balance Information for your share, share draft, loan, Money Market, and certificate accounts. - Make loan payments from your share, share draft, and Money Market accounts. - Determine if a particular item has cleared. - Verify the last date and amount of your payroll deposit. - Freeze and/or unfreeze your Family Security Credit Union Visa debit card; Your accounts can be accessed under FLASH TALK via a touch-tone telephone only. FLASH TALK service will be available for your convenience twenty-four (24) hours per day. This service may be interrupted for a short time each day for data processing. LIMITATIONS ON TRANSACTIONS - There is no limit to the number of inquiries, transfers, or withdrawal requests you may make in any one (1) day. - The Credit Union reserves the right to refuse any transaction which would draw upon insufficient funds, exceed a credit limit, lower an account below a required balance, or otherwise require us to Increase our required reserve on the account.

28 - All checks are payable to you as a primary member and will be mailed to your address of record. - The Credit Union may set other limits on the amount of any transaction, and you will be notified of those limits. - The Credit Union may refuse to honor any transaction for which you do not have sufficient available verified funds. - The service will discontinue if no transaction is entered after numerous unsuccessful attempts to enter a transaction, and there may be limits on the duration of each telephone call. See Section 2 for transfer limitations that may apply to these transactions. c. Preauthorized EFTs. - Direct Deposit. Upon Instruction of (i) your employer or (ii) the Treasury Department or (iii) other financial institutions, the Credit Union will accept direct deposits of your paycheck or federal recurring payments, such as Social Security, to your share draft account. Preauthorized Debits. Upon instruction, we will pay certain recurring transactions from your share draft account. See Section 2 for transfer limitations that may apply to these transactions. Stop Payment Rights. If you have arranged In advance to make electronic funds transfers out of your account(s) for money you owe others, you may stop payment of preauthorized transfers from your account. You must notify us orally or in writing at any time up to three (3) business days before the scheduled date of the transfer. We may require written confirmation of the stop payment order to be made within fourteen 14) days of any oral notification. If we do not receive the written confirmation, the oral stop payment order shall cease to be binding fourteen (14) days after it has been made. A stop payment request for preauthorized Electronic Fund Transfers will apply to all subsequent transfers, unless you withdraw the request. Notice of Varying Amounts. If these regular payments may vary in amount, the person you are going to pay is required to 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 payment of a preauthorized transfer 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. d. Electronic Check Conversion/Electronic Returned Check Fees. If you pay for purchases or bills with a check or share draft, you may authorize your check or share draft to be converted to an electronic funds transfer. You may also authorize merchants or other payees to electronically debit your account for returned check fees. You are considered to have authorized these electronic funds transfers if you complete the transaction after being told (orally or by a notice posted or sent to you) that the transfer may be processed electronically or if you sign a written authorization. e. Home Banking (Online Banking/Internet Banking). If we approve Home Banking for your accounts, you can access WCU s Homebanking (Online Banking) two different ways: 1.) Come into or call any WCU branch (256) or (256) ; to get your login credentials for WCU s Homebanking. A separate User ID and temporary Password will be assigned to you, which you must enter on the Existing User Login Screen located at (Choose Online Banking on WCU s website at in order to access your accounts. - WCU must have a valid address for you on file at all times to access WCU Homebanking or Mobile Apps 2) You can self-register as a New User on WCU s Homebanking Login page ( In order to login to your account as a new user you will need the following information: a.) The 5 digit WCU Account Number b.) The PIN = The LAST 4 numbers of the Primary Member's Social Security Number. c.) The Primary Member s Zip Code (Mailing Address on file with WCU) d.) The Primary Member s Date of Birth -Go to and clicking on Online Banking. -Once you are on the login screen ( -Click on New User -In the box beside Account Number - Enter the 5 digit WCU Account No. you wish to log in for. -In the box beside PIN Enter the Last 4 numbers of the Primary Member's Social Security Number. Then follow the instructions on the next screens to complete the self-registration. - WCU must have a valid address for you on file at all times to access WCU Homebanking or Mobile Apps

29 ADDRESS -WCU must have a valid up to date address on file for you in our core information system before you will be able to access WCU s Homebanking. This is necessary in order for you to be able to utilize all of WCU s Homebanking features (Example: receive estatements/enotifications, and utilize the forgot password feature). It is your responsibility to keep this information updated with WCU at all times. LOGIN CREDENTIALS -After June 2015 conversion to WCU s new Homebanking site (through Connect), ONLY Primary Account owners will have login credentials assigned to any one WCU share/savings account. No joint owners will be able to have a separate set of login credentials. CROSS ACCOUNTS -All WCU accounts/suffixes that any one WCU member s Social Security Number is attached to will show as a connected Cross Account on that member s Homebanking screen. This allows the member to have the ability to transfer funds from one account/suffix to another account/suffix at WCU Credit Union through the Credit Union s Home Banking System. NOTE: For cross-reference purposes, your account number will appear on the transaction within the statement period of the account in which you are transferring funds to. USER ID -Usernames must be between 5 to 25 characters, contain no symbols, and include at least one letter. If you forget your User ID, please call a WCU branch. RANDOM (CAPTCHA) CODES -Each time you log in to WCU Homebanking, you will be required to enter a random (CAPTCHA) code (that is case sensitive) on the screen under your User ID as an added security measure. The CAPTCHA process ensures that the person logging into WCU Homebanking is a real live human being as opposed to a computer program attempting to spam the site or user accounts and denies access to anyone who answers incorrectly. CAPTCHA stands for Completely Automated Public Turing test to tell Computers and Humans Apart. PASSWORDS -Please remember your Password and keep it secure. Your Online Banking Password ensures that only you can access your confidential information. The rules for your new password are: 8 to 25 characters containing both letters and numbers. No symbols except for the underscore. Passwords are case-sensitive. Cannot be your SSN or your Account number. Cannot be your Userid, Aaddress, nor any of your previous 3 passwords. If you enter your password wrong 3 times, your online account will be locked. You will have to call a WCU branch to have your online account unlocked and reset your password. If you forget your password, you can use the Forgot Password feature or call WCU to have it reset. We will you a temporary password to the address on record with WCU. In order to utilize this feature you will need the following information: a. Last 4 digits of primary member's Social Security Number; b. Address on file; c. Account Number; and d. Primary Member's Date of Birth (Primary Account Owner) You will be required to change your password from temporary to one you choose/create: - The first time you login to WCU s Homebanking (If WCU gave you your login credentials) - Each time you use the forgot my password feature online - If you call a WCU branch to have your password reset by WCU You may also call a WCU Branch for further assistance ( or ). MULTIFCATOR AUTHENTICATION QUESTIONS: You will be required to choose 3 Security Challenge Questions ( Multifactor Authentication ) for additional security. You can skip this the first two times you log into WCU s Homebanking. The third time you login, you will be required to choose the 3 questions & answers before you can see your account information. You will be prompted to answer these questions periodically to validate your identity when using WCU s Homebanking & Mobile Apps. Enter your answers carefully as you will need to provide the exact same answer when you are prompted with one of your challenge questions. Select a question and an answer to update your questions. Use the drop down list to choose a question and the corresponding answer. -You can change these questions & answers at any time by going to the User Options Tab & choosing Change Challenge Questions. -Security Log On Options - You can use this page to configure your log on security options. Use the security challenge section to change your challenge questions. Use the security code section if you want to receive a security code to your mobile phone/ instead of being challenged by the security questions. This feature will be available only in Online Banking. For Mobile Banking you will still be challenged with your questions. At the present time, you may use Home Banking to: - Obtain balance info & transaction history for share, share draft, loan, money market, club, IRA and certificate accounts. - Withdraw funds from your share, share draft, and Money Market accounts. - Transfer funds to & from share, share draft, and Money Market accounts (including cross-account transfers). - Schedule one-time or recurring transfers in the future (including cross-account transfers). - Make loan payments from your share, share draft, and Money Market accounts. - Determine if a particular item has cleared.

30 - View, print and download images of recently paid checks drawn on your Accounts. - Verify the last date and amount of your payroll deposit. - Submit address changes. - View, print, save, or download (Export transactions to a.csv file) account statements & tax documents. (Available only to members who have signed up & agreed to terms/conditions for E-Statements through WCU Homebanking.) Your accounts can be accessed under Home Banking via personal computer or a mobile device with internet access. Home Banking will be available for your convenience twenty-four (24) hours per day. This service may be interrupted for a short time each day for data processing. We reserve the right to refuse any transaction which would draw upon insufficient funds, exceed a credit limit, lower an account below a required balance, or otherwise require us to increase our required reserve on the account. All withdrawal checks are payable to you as a primary member and will be mailed to your address of record. We may set other limits on the amount of any transaction, and you will be notified of those limits. We may refuse to honor any transaction for which you do not have sufficient available verified funds. The service will discontinue if no transaction is entered after numerous unsuccessful attempts to enter a transaction, and there may be limits on the duration of each access. - There is no limit to the number of inquiries, transfers, or withdrawal requests you may make in any one (1) day. - No transfers will be allowed through Online Banking if any loan on your WCU Account is past due. - See Section 2 for transfer limitations that may apply to these transactions. f. Bill Pay. -We will process bill payment transfer requests only to those creditors the Credit Union has designated in the User Instructions and such creditors as you authorize and for whom the Credit Union has the proper vendor code number. We will not process any bill payment transfer if the required transaction information is incomplete. We will withdraw the designated funds from your share draft account for bill payment transfer by the designated cut-off time on the date you schedule for payment. We will process your bill payment transfer within a designated number of days before the date you are scheduled for payment. You must allow sufficient time for vendors to process your payment after they receive a transfer from us. Please leave as much time as though you were sending your payment by mail. -We cannot guarantee the time that any payment will be credited to your account by the vendor. At the present time, you may use Bill Pay to: - Initiate bill payments through our Bill Pay service -See WCU s BillPay Agreement & Disclosure online at for full details. - There is no limit on the number of bill payments per day. - See Section 2 for transfer limitations that may apply to these transactions. g. Mobile Banking (Mobile Apps) -If you have an Apple or Android device, you can access Mobile Banking by downloading the Mobile Application (App) from the Apple App Store or Android Market. -Before downloading the App you must register for WCU s Homebanking by calling or going online at and self-registering as a New User ). -See section e. Home Banking (Online Banking) above for more details. -Mobile App Login Credentials match your current WCU Homebanking (Online Banking) Login Credentials. -After registering and logging into WCU s homebanking, you will continue to log in to Mobile Banking from your App by using your WCU Homebanking User Name and Password. If you do not have an Apple or Android device you can access Homebanking (Online Banking) by going to and clicking on Online Banking and entering your WCU Homebanking User ID and Password on the existing user login screens. At the present time, you may use Mobile Banking (Mobile Apps) to: - Obtain various account information related to any of your share, share draft, money market, club, IRA, loans, or Certificate accounts (including current balances, dividends posted, loan payment amounts) - Verify the last date and amount of your payroll deposit. - Determine if a particular item has cleared. - Transfer funds between share, share draft, money market accounts. (including cross-account transfers). - Make loan payments from your share, share draft, and Money Market accounts. - Access estatements & Tax Documents for the account you are logged in for. (Available only to members who have signed up & agreed to terms/conditions for E-Statements through WCU Homebanking.) *Account History available for viewing is limited to the past 90 days. LIMITATIONS ON TRANSACTIONS Transfers from a share account, savings account or money market will be limited to six (6) total in any one calendar month. Mobile Banking is generally available 24 hours per day, seven days per week, 365 days per year; however, Mobile Banking may be interrupted without notice due to circumstanced beyond our control and for a short periods each week for data processing and/or periodically for servicing or updates. * Account History available for viewing is limited to the past 90 days.

31 - See Section 2 for transfer limitations that may apply to these transactions 2. TRANSFER LIMITATIONS Account Transfers FROM deposit Accounts that are savings or money market Accounts are limited as required by federal regulation (REG-D) to a total of six (6) transfers in any one (1) calendar month. If you exceed these limitations, your account may be subject to a fee or be closed. -You agree that we may, without notice or other obligation to you, refuse to make any Account Transfer for security reasons or as otherwise expressly provided in this Agreement or your deposit agreements with us. -No transfer or debit may exceed the available funds in your account combined with any funds available on a line of credit or any funds available per our overdraft privilege program (if applicable). -The Credit Union may, at its discretion, approve a transaction that takes an account balance negative, which would incur a standard overdraft fee. The Credit Union also reserves the right to refuse a transaction that would result in insufficient funds, draw on unavailable funds, or take an account below a required minimum balance. -No transfers will be allowed through Online Banking if any loan on your WCU Account is past due. Per Regulation D -If you exceed these limitations, your account may be subject to a fee or be closed. You may make no more than six (6) transfers and withdrawals from your Share or Money Market account to another account of yours or to a third party in any calendar month by means of: Pre-Authorized transfer or withdrawal, Automatic (ACH) transfer or withdrawal, or Internet (WCU Homebanking) transfer, or Mobile (WCU Mobile Apps) transfer, or Telephonic (either WCU Branch or FlashTalk) transfer, or by and automatic overdraft protection transfers (made to cover a check, a draft, a debit card or similar transfer order). In accordance with REGULATION D, WCU allows 6 REG-D transfers in any one calendar month, free. After the 6 th REG-D transfer in any one calendar month, you will be charged a REG-D Overdraft Transfer Fee of $35 per transfer for each additional REG-D transfer. 3. CONDITIONS OF EFT SERVICES a. Ownership of Cards. Any card or other device which we supply to you is our property and must be returned to us, or to any person whom we authorize to act as our agent, or to any person who is authorized to honor the card, immediately according to instructions. The card may be repossessed at any time at our sole discretion without demand or notice. You cannot transfer your card or account to another person. b. Honoring the Card. Neither we nor merchants authorized to honor the card will be responsible for the failure or refusal to honor the card or any other device we supply to you. If a merchant agrees to give you a refund or adjustment, you agree to accept a credit to your account in lieu of a cash refund. c. Foreign Transactions. Visa. Purchases and cash withdrawals made in foreign currencies will be debited from your account In U.S. dollars. The exchange rate between the transaction currency and the billing currency used for processing international transactions is a rate selected by Visa from a range of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa itself receives, or the government-mandated rate in effect for the applicable central processing date. The exchange rate used on the processing date may differ from the rate that would have been used on the purchase date or cardholder statement posting date. d. Security of Access Code. You may use one (i) or more access codes with your electronic funds transfers. The access codes issued to you are for your security purposes. Any codes Issued to you are confidential and should not be disclosed to third parties or recorded on or with the card. You are responsible for safekeeping your access codes. You agree not to disclose or otherwise make your access codes available to anyone not authorized to sign on your accounts. If you authorize anyone to use your access codes, that authority shall continue until you specifically revoke such authority by notifying the Credit Union. You understand that any Joint owner you authorize to use an access code may withdraw or transfer funds from any of your accounts. If you fail to maintain the security of these access codes and the Credit Union suffers a loss, we may terminate your EFT services immediately. e. Joint Accounts. If any of your accounts accessed under this agreement are joint accounts, all joint owners, including any authorized users, shall be bound by this agreement and, alone and together, shall be responsible for all EFT transactions to or from any share and share draft or loan accounts as provided in this agreement. Each joint account owner, without the consent of any other account owner, may, and is hereby authorized by every other joint account owner, make any transaction permitted under this agreement. Each joint account owner is authorized to act for the other account owners, and the Credit Union may accept orders and instructions regarding any EFT transaction on any account from any joint account owner. 4. FEES AND CHARGES There are certain fees and charges for EFT services. From time to time, the charges may be changed. We will notify you as required by applicable law. Please refer to our current Fee Schedule at for the latest up to date fees and costs for all Electronic Funds Transfer services. If you use an ATM not operated by us, you may be charged a fee by the ATM operator and by any national, regional, or local network used in processing the transaction (and you may be charged a fee for a balance inquiry even if you do not complete a funds transfer). The ATM surcharge will be debited from your account if you elect to complete the transaction or continue with the balance inquiry. a. Debit Card Fees.

32 - $1.50 ATM Withdrawal Fee / ATM Balance Inquiry Fee (at atm machines WCU does not own nonproprietary). - $20.00 Replacement Card Fee (Per Card) - $35.00 NSF Charge (Each) - $35.00 Overdraft Fee (Standard/Extended Overdraft Privilege Program JMFA) - $35.00 **Reg-D Transfer Fee (Each -after 6th REG-D transfer in one calendar month out of Share or Money Market accounts) b. FlashTalk Fees. - $35.00 NSF Charge (Return Item Fee due to non-sufficient funds on Draft/ACH/etc.) - $35.00 Overdraft Fee (Standard/Extended Overdraft Privilege Program JMFA) - $35.00 **Reg-D Transfer Fee (Each -after 6th REG-D transfer in one calendar month out of Share or Money Market accounts) c. Preauthorized EFT Fees. - $35.00 NSF Charge (Return Item Fee due to non-sufficient funds on Draft/ACH/etc.) - $35.00 *Overdraft Fee (Standard/Extended Overdraft Privilege Program JMFA) - $35.00 **Reg-D Transfer Fee (Each -after 6th REG-D transfer in one calendar month out of Share or Money Market accounts) d. HomeBanking Fees. - $35.00 NSF Charge (Return Item Fee due to non-sufficient funds on Draft/ACH/etc.) - $35.00 *Overdraft Fee (Standard/Extended Overdraft Privilege Program JMFA) - $35.00 **Reg-D Transfer Fee (Each -after 6th REG-D transfer in one calendar month out of Share or Money Market accounts) e. Bill Pay Fees. - $35.00 NSF Charge (Return Item Fee due to non-sufficient funds on Draft/ACH/etc.) - $35.00 *Overdraft Fee (Standard/Extended Overdraft Privilege Program JMFA) - $10.00 FEE FOR WRITTEN CORRESPONDENCE TO PAYEE - $10.00 FEE FOR PROOF OF PAYMENT NOT NECESSITATED BY A DISPUTE - $5.00 FEE FOR PAYMENTS RETURNED DUE TO CUSTOMER ERROR - $20.00 BILL PAY CHECK COPY FEE - $15.00 ACCOUNT RESEARCH/RECONCILIATION by wcu employee (FOR RESEARCH TIME FOR PAYMENTS NO LONGER AVAILABLE ON SCREEN HISTORY. YOU WILL BE INFORMED OF ANY SUCH CHARGES BEFORE INCURRED.) - $35.00 **Reg-D Transfer Fee (Each -after 6th REG-D transfer in one calendar month out of Share or Money Market accounts) f. Mobile Banking Fees (Mobile Apps) - $35.00 NSF Charge (Return Item Fee due to non-sufficient funds on Draft/ACH/etc.) - $35.00 *Overdraft Fee (Standard/Extended Overdraft Privilege Program JMFA) - $35.00 **Reg-D Transfer Fee (Each -after 6th REG-D transfer in one calendar month out of Share or Money Market accounts) i. Stop Payment Fee - $30.00 FEE FOR DRAFT/ACH STOP PAYMENT *Overdraft Fee (Standard/Extended overdraft privilege program JMFA) Overdrafts created by checks, in-person withdrawals, ATM withdrawals, debit card (recurring debit card payments and everyday debit card purchases), online bill pay transactions, ACH (auto debits). Please review our EFT/MAA/Funds Availability/Truth in Savings/Overdraft Policy disclosures at for more information. **Reg-D Transfer Charge -Electronic withdrawals and/or transfers from a savings or money market account are limited by Federal regulations to a total of six (6) in any one month. This limit includes transfers or withdrawals made through FlashTalk (Telephone Banking), WCU Homebanking (Online Banking), Mobile Banking (Mobile Apps), automatic payments or withdrawals, and automatic overdraft protection transfers. In accordance with REGULATION D, WCU allows 6 free REG-D transfers in any one calendar month. After the 6 th REG-D transfer in one calendar month, you will be charged a REG-D Overdraft Transfer Fee of $35 per transfer for each additional REG-D transfer *No transfer or debit may exceed the available funds in your account combined with any funds available on a line of credit or any funds available per our overdraft privilege program if applicable. *The Credit Union may, at its discretion, approve a transaction that takes an account balance negative, which would incur a standard overdraft fee. The Credit Union also reserves the right to refuse a transaction that would result in insufficient funds, draw on unavailable funds, or take an account below a required minimum balance. Depositor and each Authorized Signatory will continue to be liable, jointly and severally, for all overdraft and fee amounts, as described in the Membership and Account Agreement and Disclosure. The total (negative) balance, including all fees and charges, is due and payable upon demand. Services and fees for overdrafts are shown in the document the Credit Union uses to capture the member s opt-in choice for overdraft protection (Reg-E Consent Form What you need to know about Overdrafts & Overdraft Fees).

33 5. MEMBER LIABILITY You are responsible for all EFT transactions you authorize. If you permit someone else to use an EFT service, your card or your access code, you are responsible for any transactions they authorize or conduct on any of your accounts. TELL US AT ONCE if you believe your card has been lost or stolen, if you believe someone has used your card or access code or otherwise accessed your accounts without your authority, 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 a transaction was made with your card or card number without your permission, and was either a Visa or Interlink transaction, you will have no liability for the transaction, unless you were grossly negligent in the handling of your account or card. For all other EFT transactions, including ATM transactions or if you were grossly negligent in the handling of your account or card, your liability for an unauthorized transaction is determined as follows. If you tell us within two (2) business days you can lose no more than $50.00 if someone used your card without your permission. If you do NOT tell us within two (2) business days after you learn of the loss or theft of your card, and we can prove we could have stopped someone from using your card without your permission if you had told us, you could lose as much as $ Also, if your statement shows transfers that you did not make including those made by card, code or other means, TELL US AT ONCE. If you do not tell us within sixty (60) days after the statement was mailed to you, you may not get back any money lost after the sixty (60) days if we can prove that we could have stopped someone from making the transfers if you had told us in time. If a good reason (such as a hospital stay) kept you from telling us, we will extend the time periods. If you believe your card has been lost or stolen or that someone has transferred or may transfer money from your account without your permission, call: ( (800) (lost/stolen); or write to: WCU Credit Union, 2505 Hwy 31 South, Decatur, AL 35603; Fax: (256) You should also call the number or write to the address listed above if you believe a transfer has been made using the information from your check without your permission. 6. RIGHT TO RECEIVE DOCUMENTATION a. Periodic Statements. Transfers and withdrawals made through any ATM or POS terminal, debit card transactions, audio response transactions, preauthorized EFTs, online/pc transactions or bill payments you make will be recorded on your periodic statement. You will receive a statement monthly unless there is no transaction in a particular month. In any case, you will receive a statement at least quarterly. b. Terminal Receipt. You can get a receipt at the time you make any transaction (except inquiries) involving your account using an ATM and/or point-of-sale (POS) terminal. c. Direct Deposit. If you have arranged to have a direct deposit made to your account at least once every sixty (60) days from the same source and you do not receive a receipt (such as a pay stubs, you can find out whether or not the deposit has been made by calling (256) This does not apply to transactions occurring outside the United States. 7. ACCOUNT INFORMATION DISCLOSURE We will disclose information to third parties about your account or the transfers you make: - As necessary to complete transfers; - To verify the existence of sufficient funds to cover specific transactions upon the request of a third party, such as a credit bureau or merchant; - lf your account is eligible for emergency cash and/or emergency card replacement services, and you request such services, you agree that we may provide personal information about you and your account that Is necessary to provide you with the requested services; - To comply with government agency or court orders; or - If you give us your written permission. 8. BUSINESS DAYS Our business days are Monday through Friday, excluding holidays. 9. CREDIT UNION 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 may be liable for your losses or damages. However, we will not be liable for direct or consequential damages in the following events: - If, through no fault of ours, there is not enough money in your accounts to complete the transaction, if any funds in your accounts necessary to complete the transaction are held as uncollected funds pursuant to our Funds Availability Policy, or If the transaction involves a loan request exceeding your credit limit. - If you used your card or access code in an incorrect manner. - If the ATM where you are making the transfer does not have enough cash. - If the ATM was not working properly and you knew about the problem when you started the transaction. - If circumstances beyond our control (such as fire, flood, or power failure prevent the transaction. - If the money in your account is subject to legal process or other claim. - If fund's in your account are pledged as collateral or frozen because of a delinquent loan. - If the error was caused by a system of any participating ATM network. - If the electronic transfer is not completed as a result of your willful or negligent use of your card, access code, or any EFT facility for making such transfers. - If the telephone or computer equipment you use to conduct audio response or online/pc transactions is not working

34 properly and you know or should have known about the breakdown when you started the transaction. - If you have bill payment services, we can only confirm the amount, the participating merchant, and date of the bill payment transfer made by the Credit Union. For any other error or question you have involving the billing statement of the participating merchant, you must contact the merchant directly. We are not responsible for investigating such errors. - Any other exceptions as established by the Credit Union. 10. NOTICES - All notices from us will be effective when we have mailed them or delivered them to your last known address In the Credit Union s records. Notices from you will be effective when received by the Credit Union at the address specified in this agreement. We reserve the right to change the terms and conditions upon which this service is offered. We will mall notice to you at least twenty-one (21) days before the effective date of any change. Use of this service is subject to existing regulations governing the Credit Union account and any future changes to those regulations. The following information is a list of safety precautions regarding the use of ATMs and night deposit facilities: - Be aware of your surroundings, particularly at night. - Consider having someone accompany you when the ATM or night deposit facility is used after dark. - Close the entry door of any ATM facility equipped with a door. - If another person is uncomfortably close to you at the time of your transaction, ask the person to step back before you complete your transaction. - If it is after the regular hours of the financial Institution and you are using an ATM, do not permit entrance to any person you do not know. - Refrain from displaying your cash at the ATM or night deposit facility. As soon as your transaction is completed, place your money in your purse or wallet. Count the cash later in the safety of your car or home. - If you notice anything suspicious at the ATM or night deposit facility, consider using another ATM or night deposit facility or coming back later. - If you are in the middle of a transaction and you notice something suspicious, cancel the transaction, take your card or deposit envelope, and leave. - If you are followed after making a transaction, go to the nearest public area where people are located. - Do not write your personal identification number (PIN) or access code on your ATM card. - Report all crimes to law enforcement officials immediately. If emergency assistance is needed, call the police from the nearest available public telephone. 11. BILLING ERRORS In case of errors or questions about electronic funds transfers from your share and share draft accounts or if you need more information about a transfer on the statement or receipt, telephone us at the following number or send us a written notice to the following address as soon as you can. We must hear from you no later than sixty (60) days after we sent the first statement on which the problem appears. Call us at: or write to: WCU Credit Union, 2505 Hwy 31 South, Decatur, AL 35603; Fax: (256) Tell us your name and account number. - Describe the electronic transfer you are unsure about and explain, as clearly as you can. Why you believe the Credit Union has made an error or why you need more information. - Tell us the dollar amount of the suspected error. 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 has occurred within ten (10) business days after we hear from you and will correct airy 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 (10) business days, we may not credit your account. We will tell you the results within three (3) business days of 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 you give notice of an error within thirty (30) days after you make the first deposit to your account, we will have twenty (20) business days instead often (10) business days to Investigate the error. ** If you give notice of an error within thirty (30) days after you make the first deposit to your account, notice of an error involving a POS transaction, or notice of an error involving a transaction initiated outside the US, its possessions and territories, we will have ninety (90) days instead of forty-five (45) days to investigate the error. NOTE: If the error you assert is an unauthorized Visa transaction, other than a cash disbursement at an ATM, we will credit your account within five (5) business days unless we determine that the circumstances or your account history warrant a delay, in which case you will receive credit within ten (10) business days. 12. TERMINATION OF EFT SERVICES You may terminate this agreement or any El-T service under this agreement at any time by notifying us in writing and stopping your use of your card and any access code. You must return all cards to the Credit Union. You also agree to notify any participating merchants that authority to make bill payment transfers has been revoked. We may also terminate this agreement at any time by notifying you orally or in writing. If we terminate this agreement, we may notify any participating merchants making preauthorized debits or credits to any of your accounts that this agreement has been terminated, and that we will not accept any further preauthorized transaction instructions. We may also program our computer not to accept your card or access code for any EFT service. Whether you or the Credit Union terminates this agreement, the termination shall not affect your obligations under this agreement for any electronic transactions made prior to termination. 13. GOVERNING LAW This agreement is governed by the bylaws of the Credit Union, federal laws and regulations, the laws and regulations of the state of Alabama, and local clearinghouse rules, as amended from time to time. Any disputes regarding this agreement shall be subject to the jurisdiction of the court of the county in which the Credit Union is located, 14. ENFORCEMENT You are liable to us for any losses, costs or expenses we incur resulting from your failure to follow this agreement. You authorize us to deduct any such losses, costs or expenses from your account without prior notice to you. If we bring a legal action to collect any amount due under or to enforce this agreement, we shall be entitled, subject to applicable law, to payment of reasonable attorney s fees and costs, including fees on any appeal, bankruptcy proceedings,

35 and any post-judgment collection actions. WCU Credit Union Membership and Account Agreement: This Agreement covers your rights and responsibilities concerning your accounts and the rights and responsibilities of the Credit Union providing this Agreement (Credit Union). In this agreement, the words "you," "your," and "yours" mean anyone who signs an Account Card, Account Change Card, or any other account opening document (Account Card), or for whom membership and/or service requests are approved through the Credit Union's online application and authentication process. The words "we," "us," and "our" mean the Credit Union. The word "account" means any one (1) or more share or other accounts you have with the Credit Union. Your account type(s) and ownership features are designated by you on your Account Card or through the Credit Union's online application and authentication process. By signing an Account Card or authenticating your request, each of you, jointly and severally, agree to the terms and conditions in this Agreement, and any Account Card, Funds Availability Policy Disclosure, Truth-in-Savings Disclosure, Electronic Fund Transfers Agreement and Disclosure, Privacy Disclosure, or Account Receipt accompanying this Agreement, the Credit Union's bylaws and policies, and any amendments to these documents from time to time that collectively govern your membership and accounts. 1. MEMBERSHIP ELIGIBILITY - To join the Credit Union, you must meet the membership requirements, including purchase and maintenance of the minimum required share(s) ("membership share") as set forth in the Credit Union's bylaws. You authorize us to check your account, credit and employment history, and obtain reports from third parties, including credit reporting agencies, to verify your eligibility for the accounts and services you request. 2. INDIVIDUAL ACCOUNTS - An individual account is an account owned by one (1) member (individual, corporation, partnership, trust, or other organization) qualified for credit union membership. If the account owner dies, the interest passes, subject to applicable law, to the account owner's estate or Payable on Death (POD) beneficiary/payee or trust beneficiary, subject to other provisions of this Agreement governing our protection for honoring transfer and withdrawal requests of an owner or owner's agent prior to notice of an owner's death, and to any security interest or pledge granted by the account owner, and subject to our statutory lien rights. 3. JOINT ACCOUNTS - A joint account is an account owned by two (2) or more persons. a. Rights of Survivorship. Unless otherwise stated on the Account Card or documented through the Credit Union's online application and authentication process, a joint account includes rights of survivorship. This means that when one (1) owner dies, all sums in the account will pass to the surviving owner(s). For a joint account without rights of survivorship, the deceased owner's interest passes to his or her estate. A surviving owner's interest is subject to the Credit Union's statutory lien for the deceased owner's obligations and to any security interest or pledge granted by a deceased owner, even if a surviving owner did not consent to it. b. Control of Joint Accounts. Any owner is authorized and deemed to act for any other owner(s) and may instruct us regarding transactions and other account matters. Each owner guarantees the signature or authenticated request of any other owner(s). Any owner may withdraw or transfer funds, pledge to us all or any part of the shares, or stop payment on items without the consent of the other owner(s). We have no duty to notify any owner(s) about any transaction. We reserve the right to require written consent of all owners for any change to or termination of an account. If we receive written notice of a dispute between owners or inconsistent instructions from them, we may suspend or terminate the account and require a court order or written consent from all owners in order to act. c. Joint Account Owner Liability. If an item deposited in a joint account is returned unpaid, a joint account is overdrawn, or if we do not receive final payment on a transaction, the owners, jointly and severally, are liable to us for the amount of the returned item, overdraft, or unpaid amount and any charges, regardless of who initiated or benefited from the transaction. If any account owner is indebted to us, we may enforce our rights against any account of the indebted owner, including all funds in the joint account, regardless of who contributed the funds. 4. POD/TRUST ACCOUNT DESIGNATIONS - A Payable on Death (POD) account or trust account designation is an instruction to the Credit Union that an individual or joint account so designated is payable to the owner(s) during his, her, or their lifetimes and, when the last account owner dies, is payable to all surviving POD or trust beneficiaries/payees. Upon the death of the last account owner, if there is more than one (1) surviving beneficiary/payee, the account is owned jointly by such beneficiaries/payees without rights of survivorship. Any POD or trust beneficiary/payee designation shall not apply to Individual Retirement Accounts (IRAs). We are not obligated to notify any beneficiary/payee of the existence of any account nor the vesting of the beneficiary / payee's interest in any account, except as otherwise provided by law. This paragraph does not apply to an account held on behalf of or in the name of a trust. 5. ACCOUNTS FOR MINORS - We may require any account established by a minor to be a joint account with an owner who has reached the age of majority under state law and who shall be jointly and severally liable to us for any returned item, overdraft, or unpaid charges or amounts on such account. We may pay funds directly to the minor without regard to his or her minority. Unless a guardian or parent is an account owner, the guardian or parent shall not have any account access rights. We have no duty to inquire about the use or purpose of any transaction. We will not change the account status when the minor reaches the age of majority unless the change is authorized in writing by all account owners. 6. UNIFORM TRANSFERS/GIFTS TO MINORS ACCOUNT - A Uniform Transfers/Gifts to Minors Account (UTMA/UGMA) is an individual account created by a custodian who deposits funds as an irrevocable gift to a minor. The minor to whom the gift is made is the beneficiary of the custodial property in the account. The custodian has possession and control of the account for the exclusive right and benefit of the minor and, barring a court order otherwise, is the only party authorized to make deposits, withdrawals, or close the account. We have no duty to inquire about the use or purpose of any transaction. If the custodian dies, we may suspend the account until we receive instructions from any person authorized by law to withdraw funds or a court order authorizing withdrawals. 7. AGENCY DESIGNATION ON AN ACCOUNT - An agency designation on an account is an instruction to us that the owner

36 authorizes another person to make transactions as agent for the account owner regarding the accounts designated. An agent has no ownership interest in the account(s) or credit union voting rights. We have no duty to inquire about the use or purpose of any transaction made by the agent. 8. DEPOSIT OF FUNDS REQUIREMENTS - Funds may be deposited to any account, in any manner approved by the Credit Union in accordance with the requirements set forth in the Truth-in-Savings Disclosure. Deposits made by mail, at night depositories, or at unstaffed facilities are not our responsibility until we receive them. We reserve the right to refuse or to return any deposit. a. Endorsements. We may accept transfers, checks, drafts, and other items for deposit into any of your accounts if they are made payable to, or to the order of, one (1) or more account owners even if they are not endorsed by all payees. You authorize us to supply missing endorsements of any owners if we choose. If a check, draft, or item that is payable to two (2) or more persons is ambiguous as to whether it is payable to either or both, we may process the check, draft, or item as though it is payable to either person. If an insurance, government, or other check or draft requires an endorsement, we may require endorsement as set forth on the item. Endorsements must be made on the back of the check or draft within 1½ inches of the top edge, although we may accept endorsements outside this space. However, any loss we incur from a delay or processing error resulting from an irregular endorsement or other markings by you or any prior endorser will be your responsibility. b. Collection of Items. We act only as your agent and we are not responsible for handling items for deposit or collection beyond the exercise of ordinary care. We are not liable for the negligence of any correspondent or for loss in transit, and each correspondent will only be liable for its own negligence. We may send any item for collection. Items drawn on an institution located outside the United States are handled on a collection basis only. You waive any notice of nonpayment, dishonor, or protest regarding items we purchase or receive for credit or collection to your account. We reserve the right to pursue collection of previously dishonored items at any time, including giving a payer financial institution extra time beyond any midnight deadline limits. c. Restrictive Legends. Some checks and drafts contain restrictive legends or similar limitations on the front of the item. Examples of restrictive legends include "two signatures required," "void after 60 days," and "not valid over $ " We are not liable for payment of any check or draft contrary to a restrictive legend or other limitation contained in or on the item unless we have specifically agreed in writing to the restriction or limitation. d. Final Payment. All items or Automated Clearing House (ACH) transfers credited to your account are provisional until we receive final payment. If final payment is not received, we may charge your account for the amount of such items or ACH transfers and impose a return item charge on your account. Any collection fees we incur may be charged to your account. We reserve the right to refuse or return any item or funds transfer. e. Direct Deposits. We may offer preauthorized deposits (e.g., payroll checks, Social Security or retirement checks, or other government checks) or preauthorized transfers from other accounts. You must authorize direct deposits or preauthorized transfers by filling out a separate form. You must notify us at least 30 days in advance to cancel or change a direct deposit or transfer option. If your account is overdrawn, you authorize us to deduct the amount your account is overdrawn from any deposit, including deposits of government payments or benefits. If we are required to reimburse the U.S. Government for any benefit payment directly deposited into your account, we may deduct the amount returned from any of your accounts, unless prohibited by law. f. Crediting of Deposits. Deposits made after the deposit cutoff time and deposits made on holidays or days other than our business days will be credited to your account on the next business day. 9. ACCOUNT ACCESS - a. Authorized Signature. Your signature on the Account Card, or authentication and approval of your account, authorizes your account access. We will not be liable for refusing to honor any item or instruction if we believe the signature is not genuine. If you have authorized the use of a facsimile signature, we may honor any check or draft that appears to bear your facsimile signature, even if it was made by an unauthorized person. You authorize us to honor transactions initiated by a third person to whom you have given your account information, even if you do not authorize a particular transaction. b. Access Options. You may withdraw or transfer funds from your account(s) in any manner we permit (e.g., at an automated teller machine, in person, by mail, Internet access, Bill Pay, Mobile Banking, automatic transfer, or telephone, as applicable). We may return as unpaid any check or draft drawn on a form we do not provide, and you are responsible for any loss we incur handling such a check or draft. We have the right to review and approve any form of power of attorney and may restrict account withdrawals or transfers. We may refuse to honor a power of attorney if our refusal is conducted in accordance with applicable state law. c. Credit Union Examination. We may disregard any information on any check or draft other than the signature of the drawer, the amount, and any magnetic encoding. You agree that we do not fail to exercise ordinary care in paying an item solely because our procedures do not provide for sight examination of items. 10. FUND TRANSFERS - Except as amended by this Agreement, electronic fund transfers we permit that are subject to Article 4A of the Uniform Commercial Code will be subject to such provisions of the Uniform Commercial Code as enacted by the state where the main office of the Credit Union is located. WCU only performs Domestic wire transfers (inside the United States). We may execute certain requests for an electronic fund transfer by Fedwire. Fedwire transactions are subject to Federal Reserve Board Regulation J. You may order an electronic fund transfer to or from your account. We will debit your account for the amount of the electronic fund transfer and will charge your account for any fees related to the transfer. Unless we agree otherwise in writing, we reserve the right to refuse to execute any order to transfer funds to or from your account. We are not obligated to execute any order to transfer funds out of your account if the amount of the requested transfer plus applicable fees exceeds the available funds in your account. We are not liable for errors, delays, interruptions, or transmission failures caused by third parties or circumstances beyond our control, including mechanical, electronic, or equipment failure. We will not provide you with next day notice of ACH transfers, wire transfers, and other electronic payments credited to your account. You will receive notice of such credits on your account statements. You may contact us to determine whether a payment has been received. If we fail to properly execute a payment order, and such action results in a delay in payment to you, we will pay you dividends or interest for the period of delay as required by applicable law. The dividends or interest paid to you will be based on the lowest nominal dividend or interest rate we were paying on any account

37 during that period. Payment orders we accept will be executed within a reasonable time of receipt but may not necessarily be executed on the date they are received. Cutoff times may apply to the receipt, execution and processing of fund transfers, payment orders, cancellations, and amendments. If a request for a fund transfer, payment order, cancellation, or amendment is received after a cutoff time, it may be treated as having been received on the next fund transfer business day. Information about any cutoff times is available upon request. From time to time, we may need to suspend processing of a transaction for greater scrutiny or verification in accordance with applicable law, and this action may affect settlement or availability of the transaction. When you initiate a wire transfer, you may identify the recipient and any financial institution by name and by account or identifying number. The Credit Union and any other financial institutions facilitating the transfer may rely strictly on the account or identifying number, even if the number identifies a different person or financial institution. Any account owner may amend or cancel a payment order, even if that person did not initiate the order. We may refuse any request to amend or cancel a payment order that we believe will expose the Credit Union to liability or loss. Any request that we accept to amend or cancel a payment order will be processed within a reasonable time after it is received. You agree to hold us harmless from and indemnify us for all losses and expenses resulting from any actual or attempted amendment or cancellation of a payment order. We may require you to follow a security procedure to execute a payment order or certain electronic fund transfer transactions. We will notify you of any such security procedures. Unless we permit you to establish a different security procedure, you agree that the security procedures contained in the Credit Union's policies, of which we have notified you, are commercially reasonable verification of payment orders and other electronic fund transfers. If we permit you to establish a different security procedure, you agree that procedure is a commercially reasonable method of verifying electronic funds transfers. If we conduct a remittance transfer(s) on your behalf acting as a remittance transfer provider, such transactions will be governed by 12 C.F.R. part 1005, subpart B-Requirements for remittance transfers. A "remittance transfer" is an electronic transfer of funds of more than $15.00 which is requested by a sender and sent to a designated recipient in a foreign country by a remittance transfer provider. Terms applicable to such transactions may vary from those disclosed herein and will be disclosed to you at the time such services are requested and rendered in accordance with applicable law. 11. ACCOUNT RATES AND FEES - We pay account earnings and assess fees against your account as set forth in the Truth-in- Savings Disclosure and Schedule of Fees and Charges. We may change the Truth-in-Savings Disclosure or Schedule of Fees and Charges at any time and will notify you as required by law. 12. TRANSACTION LIMITATIONS - a. Withdrawal Restrictions. We will pay checks or drafts, permit withdrawals, and make transfers from available funds in your account. The availability of funds in your account may be delayed as described in our Funds Availability Policy Disclosure. We may also pay checks or drafts, permit withdrawals, and make transfers from your account from insufficient available funds if you have established an overdraft protection plan or, if you do not have such a plan with us, in accordance with our overdraft payment policy. We may refuse to allow a withdrawal in some situations and will advise you accordingly if: (1) there is a dispute between account owners (unless a court has ordered the Credit Union to allow the withdrawal); (2) a legal garnishment or attachment is served; (3) the account secures any obligation to us; (4) required documentation has not been presented; or (5) you fail to repay a credit union loan on time. We may require you to give written notice of seven (7) to 60 days before any intended withdrawals. b. Transfer Limitations. We may limit the dollar amount or the number of transfers from your account. Please consult your Truth-in-Savings Disclosure or your Electronic Fund Transfers Agreement and Disclosure. 13. CERTIFICATE ACCOUNTS - Any time deposit, term share, share certificate, or certificate of deposit account allowed by state law (certificate account), whichever we offer, is subject to the terms of this Agreement, the Truth-in-Savings Disclosure, and the Account Receipt for each account, the terms of which are incorporated herein by reference. 14. OVERDRAFTS - a. Payment of Overdrafts. If, on any day, the available funds in your share or deposit account are not sufficient to pay the full amount of a check, draft, transaction, or other item, plus any applicable fee that is posted to your account, we may return the item or pay it, as described below. The Credit Union's determination of an insufficient available account balance may be made at any time between presentation and the Credit Union's midnight deadline with only one review of the account required. We do not have to notify you if your account does not have sufficient available funds in order to pay an item. Your account may be subject to a charge for each item regardless of whether we pay or return the item. If we offer standard overdraft services, this service allows us to authorize payment for the following types of transactions regardless of whether your share or deposit account has sufficient funds: (1) share drafts/checks and other transactions made using your checking account, except as otherwise described below; (2) automatic bill payments; (3) ACH transactions. For ATM and one-time debit card transactions, you must affirmatively consent to such coverage. Without your consent, the Credit Union may not authorize and pay an ATM or one-time debit card transaction that will result in insufficient funds in your account. If you have established a service linking your share or deposit account with other individual or joint accounts, you authorize us to transfer funds from other another account of yours to cover an insufficient item, including transfers from a share or deposit account, an overdraft line-of-credit account, or other account you so designate. Services and fees for these transactions are shown in the document the Credit Union uses to capture your affirmative consent and the Schedule of Fees and Charges. Except as otherwise agreed in writing, if we exercise our right to use our discretion to pay such items that result in an insufficiency of funds in your account, we do not agree to pay them in the future and may discontinue coverage at any time without notice. If we pay these items or impose a fee that results in insufficient funds in your account, you agree to pay the insufficient amount, including the fee assessed by us, in accordance with our standard overdraft services or any other service you may have authorized with us, or if you do not have such protections with us, in accordance with any overdraft payment policy we have, as applicable. b. Order of Payments. Checks, drafts, transactions, and other items may not be processed in the order that you make them or in the order that we receive them. We may, at our discretion, pay a check, draft, or item, and execute other transactions on your account in any order we choose. The order in which we process checks,

38 drafts, or items, and execute other transactions on your account may affect the total amount of overdraft fees that may be charged to your account. Please contact us if you have questions about how we pay checks or drafts and process transfers and withdrawals. 15. POSTDATED AND STALEDATED CHECKS OR DRAFTS - You agree not to issue any check or draft that is payable on a future date (postdated). If you do issue a check or draft that is postdated and we pay it before that date, you agree that we shall have no liability to you for such payment. You agree not to deposit checks, drafts, or other items before they are properly payable. We are not obligated to pay any check or draft drawn on your account that is presented more than six (6) months past its date. 16. STOP PAYMENT ORDERS - a. Stop Payment Order Request. Any owner may request a stop payment order on any check or draft drawn on the owner's account. To be binding, the order must be in writing, dated and signed, and must accurately describe the check or draft, including the exact account number, the check or draft number, and the exact amount of the check or draft. This exact information is necessary for the Credit Union's computer to identify the check or draft. If we receive incorrect or incomplete information, we will not be responsible for failing to stop payment on the check or draft. In addition, we must receive sufficient advance notice of the stop payment order to allow us a reasonable opportunity to act on it. If we re-credit your account after paying a check or draft over a valid and timely stop payment order, you agree to sign a statement describing the dispute with the payee, to assign to us all of your rights against the payee or other holders of the check or draft, and to assist us in any legal action. b. Duration of Order. Oral stop payment orders for check or drafts will lapse within 14 calendar days unless confirmed in writing within that time. Written stop payment orders for checks or drafts are effective for six (6) months and may be renewed for additional six (6) month periods by requesting in writing that the stop payment order be renewed within a period during which the stop payment order is effective. We are not required to notify you when a stop payment order expires. c. Liability. Fees for stop payment orders are set forth in the Truth-in-Savings Disclosure or Schedule of Fees and Charges. You may not stop payment on any certified check, cashier's check, teller's check, or any other check, draft, or payment guaranteed by us. Although payment of an item may be stopped, you may remain liable to any item holder, including us. You agree to indemnify and hold the Credit Union harmless from all costs, including attorney's fees, damages, or claims related to our refusing payment of an item, including claims of any joint account owner, payee, or endorsee in failing to stop payment of an item as a result of incorrect information provided by you. 17. CREDIT UNION LIABILITY - If we do not properly complete a transaction according to this Agreement, we will be liable for your losses or damages not to exceed the amount of the transaction, except as otherwise provided by law. We will not be liable if: (1) your account contains insufficient funds for the transaction; (2) circumstances beyond our control prevent the transaction; (3) your loss is caused by your or another financial institution's negligence; or (4) your account funds are subject to legal process or other claim. We will not be liable for consequential damages, except liability for wrongful dishonor. We exercise ordinary care if our actions or Non-actions are consistent with applicable state law, Federal Reserve regulations and operating letters, clearinghouse rules, and general financial institution practices followed in the area we serve. You grant us the right, in making payments of deposited funds, to rely exclusively on the form of the account and the terms of this Agreement. Any conflict regarding what you and our employees say or write will be resolved by reference to this Agreement. 18. CHECKS OR DRAFTS PRESENTED FOR PAYMENT IN PERSON - We may refuse to accept any check or draft drawn on your account that is presented for payment in person. Such refusal shall not constitute a wrongful dishonor of the check or draft, and we shall have no liability for refusing payment. If we agree to cash a check or draft that is presented for payment in person, we may require the presenter to pay a fee. Any applicable check or draft cashing fees are stated in the Schedule of Fees and Charges. 19. REMOTELY CREATED CHECKS OR DRAFTS - For purposes of this paragraph, "account" means a transaction account, credit account, or any other account on which checks or drafts may be drawn. A remotely created check or draft is a check or draft created by someone other than the person on whose account the check or draft is drawn. A remotely created check or draft is generally created by a third party payee as authorized by the owner of the account on which the check or draft is drawn. Authorization is usually made over the telephone or through on-line communication. The owner of the account does not sign a remotely created check or draft. In place of the owner's signature, the remotely created check or draft usually bears a statement that the owner authorized the check or draft or bears the owner's printed or typed name. If you authorize a third party to draw a remotely created check or draft against your account, you may not later revoke or change your authorization. It is your responsibility to resolve any authorization issues directly with the third party. We are not required to credit your account and may charge against your account any remotely created check or draft for which the third party has proof of your authorization. 20. PLEDGE/STATUTORY LIEN - Unless prohibited by law, you pledge and grant as security for all obligations you may have now or in the future, except obligations secured by your principal residence, all shares and dividends and all deposits and interest, if any, in all accounts you have with us now and in the future. If you pledge a specific dollar amount in your account(s) for a loan, we will freeze the funds in your account(s) to the extent of the outstanding balance of the loan or, if greater, the amount of the pledge if the loan is a revolving loan. Otherwise, funds in your pledged account(s) may be withdrawn unless you are in default. Federal or state law (depending upon whether we have a federal or state charter) gives us a lien on all shares and dividends and all deposits and interest, if any, in accounts you have with us now and in the future. Except as limited by federal or state law, the statutory lien gives us the right to apply the balance of all your accounts to any obligation on which you are in default. After you are in default, we may exercise our statutory lien rights without further notice to you. Your pledge and our statutory lien rights will allow us to apply the funds in your account(s) to what you owe when you are in default, except as limited by federal or state law. If we do not apply the funds in your account(s) to satisfy your obligation, we may place an administrative freeze on your account(s) in order to protect our statutory lien rights and may apply the funds in your account(s) to the amount you owe us at a later time. The statutory lien and your pledge do not

39 apply to any Individual Retirement Account or any other account that would lose special tax treatment under federal or state law if given as security. By not enforcing our right to apply funds in your account to your obligations that are in default, we do not waive our right to enforce these rights at a later time. 21. LEGAL PROCESS - If any legal action is brought against your account, we may pay out funds according to the terms of the action or refuse any payout until the dispute is resolved, as permitted by law. Any expenses or attorney fees we incur responding to legal process may be charged against your account without notice, unless prohibited by law. Any legal process against your account is subject to our lien and security interest. 22. ACCOUNT INFORMATION - Upon request, we will give you the name and address of each agency from which we obtain a credit report regarding your account. We agree not to disclose account information to third parties except when: (1) it is necessary to complete a transaction; (2) the third party seeks to verify the existence or condition of your account in accordance with applicable law; (3) such disclosure complies with the law or a government agency or court order; or (4) you give us written permission. 23. NOTICES - a. Name or Address Changes. You are responsible for notifying us of any name or address change. The Credit Union is only required to attempt to communicate with you at the most recent address you have provided to us. We may require all name and address changes to be provided in writing. If we attempt to locate you, we may impose a service fee as set forth in the Truth-in-Savings Disclosure or Schedule of Fees and Charges. b. Notice of Amendments. Except as prohibited by applicable law, we may change the terms of this Agreement at any time. We will notify you of any change in terms, rates, or fees as required by law. We reserve the right to waive any terms of this Agreement. Any such waiver shall not affect our right to future enforcement. c. Effect of Notice. Any written notice you give us is effective when we receive it. Any written notice we give to you is effective when it is deposited in the U.S. mail, postage prepaid, and addressed to you at your statement mailing address. Notice to any account owner is considered notice to all account owners. d. Electronic Notices. If you have agreed to receive notices electronically, we may send you notices electronically and discontinue mailing paper notices to you until you notify us that you wish to reinstate receiving paper notices. 24. TAXPAYER IDENTIFICATION NUMBER AND BACKUP WITHHOLDING - Your failure to furnish a correct Taxpayer Identification Number (TIN) or meet other requirements may result in backup withholding. If your account is subject to backup withholding, we must withhold and pay to the Internal Revenue Service (IRS) a percentage of dividends, interest, and certain other payments. If you fail to provide your TIN, we may suspend opening your account. 25. STATEMENTS a. Contents. If we provide a periodic statement for your account, you will receive a periodic statement of transactions and activity on your account during the statement period as required by applicable law. If a periodic statement is provided, you agree that only one (1) statement is necessary for joint accounts. For share draft or checking accounts, you understand and agree that our original check or draft, when paid, becomes property of the Credit Union and may not be returned to you, but copies of the check or draft may be retained by us or by payable-through financial institutions and may be made available upon your request. You understand and agree that statements are made available to you on the date they are sent to you. You also understand and agree that checks, drafts, or copies thereof are made available to you on the date the statement is sent to you, even if the checks or drafts do not accompany the statement. b. Examination. You are responsible for promptly examining each statement upon receiving it and reporting any irregularities to us. If you fail to report any irregularities such as forged, altered, unauthorized, unsigned, or otherwise fraudulent items drawn on your account, erroneous payments or transactions, or other discrepancies reflected on your statement within 33 days of the date we sent the statement to you, we will not be responsible for your loss. We also will not be liable for any items that are forged or altered in a manner not detectable by a reasonable person, including the unauthorized use of a facsimile signature machine. c. Notice to Credit Union. You agree that the Credit Union's retention of checks or drafts does not alter or waive your responsibility to examine your statements or the time limit for notifying us of any errors. The statement will be considered correct for all purposes, and we will not be liable for any payment made or charge to your account unless you notify us in writing within the above time limit for notifying us of any errors. If you fail to receive a periodic statement, you agree to notify us within 14 days of the time you regularly receive a statement. 26. DORMANT/INACTIVE OR ABANDONED ACCOUNTS - If your account falls below any applicable minimum balance and you have not made any transactions over a period specified in the Truth-in-Savings Disclosure or Schedule of Fees and Charges, we may classify your account as Dormant/Inactive or Abandoned. Unless prohibited by applicable law, we may charge a service fee, as set forth in the Truth-in-Savings Disclosure or Schedule of Fees and Charges, for processing your Dormant/Inactive or Abandoned account. If we impose a fee, we will notify you, as required by law, at your last known address. You authorize us to transfer funds from another account of yours to cover any service fees, if applicable. To the extent allowed by law, we reserve the right to transfer the account funds to an account payable and to suspend any further account statements. If a deposit or withdrawal has not been made on the account and we have had no other sufficient contact with you within the period specified by state law, the account will be presumed to be abandoned. Funds in abandoned accounts will be reported and remitted (Escheated) in accordance with state law. Once funds have been turned over to the state, we have no further liability to you for such funds, and if you choose to reclaim such funds, you must apply to the appropriate state agency. Dormant Account FEE: A Dormant Account fee of $10.00 per year will be charged to the member s account, if member initiated activity has not been made within 30 days of the date of the Dormancy Notice. If the account balance is below the maximum fee amount, the Dormant Account Fee will equal the available funds remaining. The Credit Union will allow the Dormant Account Fee to draw the account balance to zero. Any account with a zero balance and no member initiated activity for 12 months may be closed by the Credit Union. These fees will be posted on the Credit Union s fee schedule and may be adjusted by the Board at any time. Escheatment FEE: An Escheatment fee of $25.00 per member on any account(s) will be charged to the member s account at the time the account is reported to the State of Alabama for Escheatment purposes. If the account balance is below the maximum fee amount, the fee will equal the available funds

40 remaining. The account(s) will be closed, if the account has been abandoned for the period of time specified in the Alabama Unclaimed Property Law. These fees will be posted on the Credit Union s fee schedule and may be adjusted by the Board at any time. PLEASE SEE WCU S TRUTH IN SAVINGS DISCLOSURE FOR WCU S DORMANT ACCOUNT POLICY. 27. SPECIAL ACCOUNT INSTRUCTIONS - You may request that we facilitate certain trust, will, or court-ordered account arrangements. However, because we do not give legal advice, we cannot counsel you as to which account arrangement most appropriately meets the specific requirements of your trust, will, or court order. If you ask us to follow any instructions that we believe might expose us to claims, lawsuits, expenses, liabilities, or damages, whether directly or indirectly, we may refuse to follow your instructions or may require you to indemnify us or post a bond or provide us with other protection. We may require that account changes requested by you, or any account owner, such as adding or closing an account or service, be evidenced by a signed Account Change Card or other document which evidences a change to an account and accepted by us. 28. TERMINATION OF ACCOUNT - We may terminate your account at any time without notice to you or may require you to close your account and apply for a new account if: (1) there is a change in owners or authorized signers; (2) there has been a forgery or fraud reported or committed involving your account; (3) there is a dispute as to the ownership of the account or of the funds in the account; (4) any checks or drafts are lost or stolen; (5) there are excessive returned unpaid items not covered by an overdraft protection plan; (6) there has been any misrepresentation or any other abuse of any of your accounts; or (7) we reasonably deem it necessary to prevent a loss to us. You may terminate an individual account by giving written notice. We reserve the right to require the consent of all owners to terminate a joint account. We are not responsible for payment of any check, draft, withdrawal, transaction, or other item after your account is terminated; however, if we pay an item after termination, you agree to reimburse us. 29. TERMINATION OF MEMBERSHIP - You may terminate your membership by giving us written notice or by withdrawing your minimum required membership share(s), if any, and closing all your accounts. You may be denied services for causing a loss to the Credit Union, or you may be expelled for any reason as allowed by applicable law. 30. DEATH OF ACCOUNT OWNER - We may continue to honor all transfer orders, withdrawals, deposits, and other transactions on an account until we know of a member's death. Once we know of a member's death, we may pay checks or drafts or honor other payments or transfer orders authorized by the deceased member for a period of ten (10) days after that date unless we receive instructions from any person claiming an interest in the account to stop payment on the checks, drafts, or other items. We may require anyone claiming a deceased owner's account funds to indemnify us for any losses resulting from our honoring that claim. This Agreement will be binding upon any heirs or legal representatives of any account owner. 31. UNLAWFUL INTERNET GAMBLING AND OTHER ILLEGAL ACTIVITIES - You agree that you are not engaged in unlawful Internet gambling or any other illegal activity. You agree that you will not use any of your accounts, access devices or services for unlawful Internet gambling or other illegal activities. We may terminate your account relationship if you engage in unlawful Internet gambling or other illegal activities. 32. SEVERABILITY - If a court holds any portion of this Agreement to be invalid or unenforceable, the remainder of this Agreement shall not be invalid or unenforceable and will continue in full force and effect. All headings are intended for reference only and are not to be construed as part of the Agreement. 33. ENFORCEMENT - You are liable to us for any losses, costs, or expenses we incur resulting from your failure to follow this Agreement. You authorize us to deduct any such losses, costs, or expenses from your account without prior notice to you. If we bring a legal action to collect any amount due under or to enforce this Agreement, we shall be entitled, subject to applicable law, to payment of reasonable attorney's fees and costs, including fees on any appeal, bankruptcy proceedings, and any post judgment collection actions. 34. GOVERNING LAW - This Agreement is governed by the Credit Union's bylaws, federal laws and regulations, the laws, including applicable principles of contract law, and regulations of the state in which the Credit Union's main office is located, and local clearinghouse rules, as amended from time to time. As permitted by applicable law, you agree that any legal action regarding this Agreement shall be brought in the county in which the Credit Union is located. 35. NEGATIVE INFORMATION NOTICE - We may report information about your loan, share, or deposit accounts to credit bureaus. Late payments, missed payments, or other defaults on your accounts may be reflected in your credit report. 36. ARBITRATION Any controversy or claim arising out of or relating to your membership, account, services obligations and/or transactions including lending transactions (except mortgage transactions) shall be settled by binding arbitration following the rules of the American Arbitration Association and judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. The arbitrator shall determine the prevailing party, and the costs and expenses of the arbitration proceeding, including the arbitrator's fees, shall be borne by the non-prevailing party, unless otherwise required by law. No provision of this Agreement, nor the exercise of any right under this agreement, shall waive the arbitration requirement or limit the right of the Credit Union to: (I) obtain provisional or ancillary remedies, such as injunctive relief, writ of attachment, or protective order from a court having jurisdiction before, during, or after the pendency of any arbitration, (2) exercise self-help remedies, such as set-off; (3) evict, foreclose against or sell any real or personal property collateral by the exercise of a power of sale under a mortgage or other security agreement or instrument, a deed of trust, or applicable law; (4) exercise any other rights under this agreement upon the breach of any term or condition herein; or, (5) to proceed with collection of the Account through all other legal methods, including, but not limited to, proceeding in court to obtain judgment. Any and all arbitration under this contract will take place on an individual basis; class arbitrations and class actions are not permitted, and any arbitration shall be exclusively conducted in Morgan County, Alabama. YOU FURTHER AGREE THAT YOU ARE WAIVING YOUR RIGHT TO TRIAL BY JURY AND TO PARTICIPATE IN A CLASS ACTION. 1993, 95, 96, 99, 2000, 03-07, 09, 10, 13 All Rights Reserved D1000A-e

41 General Policy Statement: WCU Credit Union Funds Availability Policy Regulation CC (12 CFR Part 229) sets minimum standards for when deposited funds must be made available to members. WCU Credit Union offers same day or next day availability for most funds deposited with the Credit Union and provides funds availability disclosures required by the Regulation. Guidelines: 1. DEFINITIONS A. Account. A transaction account. An account generally includes those from which the accountholder is permitted to make transfers or withdrawals by negotiable instruments, payment order of withdrawal, telephone transfer, electronic payment, or other form of transfer. Account does NOT include a savings account. B. Availability. For determining the availability of a deposit, every day is a business day, except Saturdays, Sundays and federal holidays. If a federal holiday falls on a Sunday, the next day is not a business day. If a member makes a deposit before 5:00 pm on a business day that the Credit Union is open, the Credit Union will consider that day to be the day of deposit. However, if a member makes a deposit after 5:00 pm or on a day the Credit Union is not open, the Credit Union will consider the deposit to have been made on the next business day that the Credit Union is open. 2. SAME-DAY AVAILABILITY. Cash and Federal government payments made by the automated clearinghouse method, such as Social Security payments, SSI payments, IRS tax refunds, and federal government salary payments, must be made available on the day funds are received or, if the funds are not received on a business day, on the next business day. (See 31 CFR Part 210, "Federal Payments through Financial Institutions by the Automated Clearing House Method." sections 210.2, ) 3. NEXT DAY AVAILABILITY. The following funds deposited into a member's account must be available by the next business day: A. Cash deposited in person at a teller station. To qualify for next-day availability, members must deposit funds during Credit Union business hours before the cutoff time for receiving deposits. B. Electronic payments (e.g., wire transfers, automated clearinghouse credit transfers). These are considered "received" when the Credit Union has received both: i. Payment in finally collected funds, and Payment instructions indicating the account and the amount to be credited. C. U.S. Treasury checks deposited into the payee's account. D. The following types of checks, if deposited in person at a teller station into the payee's account: i. U.S. Postal Service Money Orders. i iv. Federal Reserve Bank checks/federal Home Loan Bank check. State and local government checks, if the Credit Union is located in the same state as the government entity that issued the check and if the check was accompanied by any special deposit slip required by the Credit Union. Cashier's, certified, or teller's checks, if accompanied by any required special deposit slip. E. "On us" checks, i.e., checks drawn on the Credit Union or one of its branches. F. Drafts covered by member s account, such as situations where the member s account balance exceeds the amount of the draft. G. For checks not described above, the lesser of $200 or the aggregate amount of such checks must be available, except that: i. If the member receives cash at the time of the deposit, the amount of cash received is not required to be credited. For example, if the member deposits a $300 check and receives $100 cash back, the

42 Credit Union need not make an additional $200 available for withdrawal the following day. If the member has a negative book balance or a negative available balance in the account at the time of the deposit, the $200 that must be available on the next business day may be made available by applying $200 to the negative balance, rather than making $200 available for withdrawal. 4. SECOND DAY AVAILABILITY. The following funds deposited into a member's account must be made available no later than the second business day following the deposit. A. Funds that would otherwise qualify for next-day availability, except for the fact that funds are not deposited in person at a teller station, i.e., they are deposited by mail or in an ATM owned by the Credit Union. 5. FIFTH-DAY AVAILABILITY. Cash or checks deposited into a nonproprietary ATM must be made available no later than the fifth business day following the deposit. A. Up to $400 of the deposited funds must be available by 5 p.m. on the day the funds would be made available under the schedule. Cash withdrawals for the remainder of the funds (over the initial $400) can be delayed until the following business day. 6. ADDING A DAY TO AVAILABILITY PERIOD. The availability period may be extended by one day for a deposit that is made to a Credit Union located in Hawaii or Alaska, is not subject to next-day availability, and is by check drawn on a paying bank not located in the same state as the Credit Union. 7. "CASE-BY-CASE" HOLDS. If a Credit Union has a policy of making funds available sooner than required by the foregoing rules, the Credit Union may extend the time when funds are available up to the time periods allowed above on a case-by-case basis, subject to the following requirements. A. Initial Disclosure. Before opening a new account, the Credit Union must disclose its case-by-case hold policy. B. Notice at Time of Hold. The Credit Union must also provide the member with notice at the time of the deposit. i. Content. The notice must state: 1. Statement that the Credit Union is holding the funds. 2. The account number. 3. The date of the deposit. 4. The amount of the deposit that is being delayed. 5. When the funds will be available for withdrawal. 6. How to obtain a refund of returned check fees or overdraft fees if the notice is not given at the time of the deposit, and the check is paid. When Given. Ordinarily, notice is given when deposit is made. If the deposit is not made in person, notice should be given no later than the first business day thereafter. 8. "SPECIFIC EXCEPTION" HOLDS. 1. If the notice is not provided at the time of deposit, no overdraft fees may be assessed if the overdraft would not have occurred except for the delay of funds availability and the check was paid. Overdraft fees may be assessed if the institution provides notice of such fees at the time the notice of delayed funds is given, and is willing to refund such fees upon request by the member. A. Description. The following situations create a "specific exception" to the funds availability rules: i. Large Deposits. A member's aggregate deposits in one day exceed $5,000. (The exception applies to the amount over $5,000. The Credit Union may apply this exception to the aggregate deposits to all accounts held by the member, without regard to joint accountholders. Re-deposited Checks. A check has been returned unpaid and re-deposited, unless the reason the check was returned was because it was missing an endorsement or was postdated. $200 of the deposit does not have to be made available on the next business day. The business day the check is

43 re-deposited is considered to be the day of deposit. i iv. Repeated Overdrafts. Within the last six months, a member's account has been overdrawn six or more times, or overdrawn twice by more than $5,000 for two or more business days (or would have been had the checks and charges been paid). This exception does NOT apply to any next-day availability deposits, despite an overdrawn account. An account will retain its repeated overdraft status for six months from the last overdraft. Reasonable Cause to Doubt Collectibility. The Credit Union has reasonable cause to believe the check is uncollectible, such as a stale or postdated check, evidence of check kiting, or a notice dishonor from the payor financial institution. The Credit Union will maintain the notice provided to the member, along with a statement of facts surrounding its reason to doubt the collectibility of the item, for 2 years. v. Emergency Conditions, such as telecommunication or computer breakdowns, war, or some other emergency condition beyond the Credit Union's control. A hold will be placed on the funds for a reasonable time after the emergency has passed. B. Effect. If an exception applies, the Credit Union may: i. Add one business day for "on us" checks. i Ignore next-day availability requirement for U.S. Treasury checks, U.S. Postal Service money orders, Federal Reserve Bank checks, Federal Home Loan bank checks, state and local government checks, and cashier's, certified, and teller's checks, and treat them as being subject to the availability requirements for local or non-local checks set forth in the immediately following paragraphs. Add five business days, thus making them available within 7 business days. C. Notice Requirement. The Credit Union may not place a specific exception hold unless it notifies the member that the exception is being invoked. i. Content. The notice must state: 1. The member s name and account number. 2. The date of the deposit. 3. The amount of the deposit being delayed. 4. Statement that the Credit Union is holding funds. 5. What the exception is and why it is being invoked. 6. When the funds will be available for withdrawal. 7. How to obtain a refund of returned check fees or overdraft fees if the notice is not given at the time of the deposit, and the check is paid. i When Given. Ordinarily, notice must be given when the deposit is made. If the facts giving rise the exception are not known until after the deposit is made, then notice must be given no later than one business day thereafter. How Given. Notice can be delivered personally to the member when the deposit is made, mailed, or faxed. In addition, it can be delivered by if the member agrees to receive s and if the e- mail can be downloaded and printed. 9. NEW ACCOUNTS. Special rules apply for new accounts (sole account with the Credit Union less than 30 days old, provided none of the members on the account have other transaction accounts at the Credit Union that have been opened for at least 30 days). A. Cash deposits and wire transfers are subject to the next-day availability requirements. B. The first $5,000 of deposits of U.S. Treasury checks must be made available on the next business day. Any amount over $5,000 into a new account may be held until the 9th business day. C. The first $5,000 of an in-person deposit of checks drawn on Federal Reserve Banks and Federal Home Loan Banks, state and local government checks, cashier's checks, certified checks, teller's checks, and, for the

44 purposes of the new account exception only, traveler's checks, must be made available on the next business day. The first $5,000 of such deposits not made in person must be made available on the second business day. The remainder may be held until the 9th business day. D. Next-day availability is not required for "on us" checks or the first $200 of a day's deposit. E. Fifth-day availability requirements do not apply. 10. INITIAL DISCLOSURE. Before opening a new account, a Credit Union must provide to the member a disclosure that clearly and conspicuously explains the Credit Union s funds availability policy complying with 12 CFR Section The Credit Union will use one of the model policies below or develop their own that is substantially similar. A. Model Policy C-1: Next-day availability B. Model Policy C-2: Next-day availability and specific exceptions C. Model Policy C-3: Next-day availability, case-by-case holds to statutory limits, and specific exceptions D. Model Policy C-4: Holds to statutory limits on all deposits (includes chart) E. Model Policy C-5: Holds to statutory limits on all deposits 11. OTHER DISCLOSURES. A Credit Union must also: A. Provide a copy of its funds availability policy to a member who requests it. B. Post a copy of its funds availability policy at every location where deposits are accepted, including ATMs. The Credit Union will also post its availability policy on its website on every page where accounts are opened and/or payments are made online. C. Notify its members of a change in the funds availability policy at least 30 days prior to the change. If the change expedites the availability of funds, the Credit Union may provide the notice 30 days after the change is implemented. 12. DEPOSIT RECONCILIATION. Credit discrepancies that are not appropriately reconciled within prescribed timeframes governed under Reg CC, may leave members without timely access to their funds and in violation of the regulation. The Credit Union will have procedures in place to assist employees in processing transactions, reporting discrepancies, taking appropriate steps to determine the cause of the discrepancy and appropriately reconcile any discrepancy identified within appropriate timeframes. The Credit Union will also provide appropriate training and oversight to ensure compliance with applicable policies and procedures. 13. CIVIL LIABILITY. Violation of Reg CC may result in liability by the Credit Union for actual damages and additional amounts not less than $100 nor greater than $1,000 for individuals and a maximum of $500,000 or one percent of net worth for class actions. 14. TWO-YEAR RECORD RETENTION. A Credit Union must retain records showing compliance with Reg CC for at least two years (See Section 10000, Table 11). 15. PAYING BANK S RESPONSIBILITY FOR THE RETURN OF CHECKS. A paying credit union that decides not to pay a check must return the check in an expeditious manner, meaning returned to the depositary institution by 4:00 p.m. (local time of the depositary institution) on the 2nd business day after the banking day on which the check was presented to the paying credit union. A. Forward Collection Test. Because the above test is sometimes difficult to meet, under the forward collection test, a paying credit union (or returning credit union) returns a check expeditiously if it returns a check by means as swift as the means a similarly situated institution would use for the forward collection of a check. B. Unidentifiable Depositary Institution. When a paying credit union cannot identify the depositary institution may send the check to any financial institution that handled the check for forward collection, and must also advise the financial institution to which the check is sent that the paying credit union is unable to identify the depositary institution. C. Identification of Returned Checks. A returned check must be clearly marked on its face that it is being returned, along with the reason for the return. If a check is unavailable for return, either a copy of the front and back of the check, or a written notice of nonpayment containing the following information must be provided instead:

45 i. The name and routing number of the paying institution; i iv. The name of the payee(s); The amount; The date of the endorsement of the depositary institution; v. The account number of the member(s) or customer(s) of the depositary institution; vi. v vi The branch name or number of the depositary institution from its endorsement; The trace number associated with the endorsement of the depositary institution; and The reason for nonpayment. 16. RETURNING BANK S RESPONSIBILITY FOR RETURN OF CHECKS. The responsibility of the returning institution for the return of checks is the same as it is for paying credit institutions above. 17. DEPOSITARY BANK S RESPONSIBILITY FOR RETURNED CHECKS. A. Acceptance of Returned Checks. A depositary institution should accept returned checks and written notices of nonpayment: i. At a location requested by the depositary institution for presentment of checks for forward collection; and i iv. At a branch, head office, or other location consistent with the name and address of the institution in its endorsement on the check. If no address appears in the endorsement, at a branch or main office associated with the routing number of the institution on its check endorsement. At any branch or main office, if no routing number or address appears in the endorsement. B. Payment. A depositary credit union must pay the returning institution or paying institution returning the check to it for the amount of the check prior to the close of business on the banking day the check is received. Payment may be made by: i. Debit to an account of the depositary institution on the books of the returning or paying institution; i iv. Cash; Wire transfer; or Any other form of payment acceptable to the returning or paying institution. C. Misrouted Returned Checks and Written Notices of Nonpayment. If the Credit Union receives a returned check or written notice of nonpayment on the basis that it is the depositary institution, and the Credit Union determines that it is not the depositary institution, it must promptly return the check or notice to the actual depositary institution or to a returning bank that agrees to handle the returned check. D. Charges. A depositary institution may not impose a fee for accepting and paying checks being returned to it. 18. NOTICE OF NONPAYMENT. A. If a paying credit union decides not to pay a check equal to or greater than $2,500, it must provide a notice of nonpayment to the depositary bank prior to 4:00 p.m. on the 2nd business day following the business day the check was received. Notice may be provided by returning the check, by a written notice, by telephone, Fedwire, or telex. B. Content of Notice. The notice must include the following: i. The name and routing number of the paying institution; The name of the payee(s);

46 i iv. The amount; The date of the endorsement of the depositary institution; v. The account number of the member(s) or customer(s) of the depositary institution; vi. v vi Branch name or number of the depositary institution from its endorsement; The trace number associated with the endorsement of the depositary institution; and The reason for nonpayment. C. Acceptance of Notice. The depositary institution must accept notices during business days either at the telephone number indicated in the indorsement at its general purpose telephone number or at any other number provided for receipt of notice. D. Notification to the Member. When the depositary credit union receives a returned check or notice of nonpayment, it must send its member a notice by midnight of the business day following the day the check or notice was received. 19. WARRANTIES. A. Each paying or returning institution that transfers a returned check and receives a settlement or other consideration for it, warrants to the transferee returning institution, to any subsequent returning institution, to the depositary institution, and to the owner of the check the following: i. The paying institution returned the check within its deadline under the UCC, Regulation J (12 CFR 210); i iv. It is authorized to return the check or to send notice; The check has not been materially altered; and In the case of a notice in lieu of return, the original check has not and will not be returned. B. The above warranties do not apply to checks drawn on the U.S. Treasury, U.S. Postal Service money orders, or checks drawn on a state or local governments that are not payable through or at a bank. C. Each institution that presents checks for payment and in return receives a settlement, warrants to the paying institution that the total amount of the checks presented is equal to the total amount of the settlement demanded. D. Each institution that transfers checks to a collecting, returning or depositary institution and in return receives a settlement, warrants that the accompanying information accurately indicates the total amount of the checks or returned checks transferred. E. Each institution that presents or transfers a check warrants that the information encoded after issue in magnetic ink on the check or returned check is correct. F. Damages for breach of these warranties must not exceed the consideration received by the institution plus interest and expenses related to the check. G. Transfer and Presentment Warranties for Remotely-Created Checks. i. A financial institution that transfers or presents a remotely created check and receives a settlement or other consideration warrants to the transferee institution, any collecting institution, and the paying institution that the person on whose account the remotely created check is drawn authorized the issuance of the check in the amount stated on the check and authorized payment to the payee stated on the check. If a paying institution files a claim for breach of warranty with respect to a remotely created check, the warranting institution may defend by proving that the paying institution s customer is prevented under UCC from claiming that issuance of the check was unauthorized. For example, this may be the case where the customer failed to discover the unauthorized remotely created check in a timely manner. 20. ENDORSEMENTS.

47 A. Endorsement Standards. Financial institutions are required to use a standard form of endorsement when endorsing checks during the forward-collection and return process. The standard provides for endorsements by all collecting and returning institutions, with unique requirements for depositary institutions. These standards are designed to facilitate faster handling of returned checks and the identification of the depositary institution. The standards include requirements for the location, content, and ink color of the endorsement. The standards would apply to any credit union that: i. Accepts items for deposit or cash; i Is involved in the forward collection process; or Accepts deposits of return items for subsequent presentment to another returning institution or depositary institution. B. Depositary Credit Union Endorsement. i. Location. The endorsement must be located in the space on the back of the check that is three inches from the leading edge and one and one-half inches from the trailing edge of the check so that the routing number is wholly contained in the area. Content. The endorsement must contain the following information: 1. The institutions nine-digit routing number (set off by arrows at each end of the number toward the number); 2. The institution name and location; 3. The endorsement date; 4. The endorsement may also contain the following information: a. A branch identification; b. The institution s trace/sequence number; c. The institution s telephone number for receipt of notification of large-dollar returned checks; and d. Other optional information provided that such information does not interfere with the readability of the endorsement. i Color. The endorsement of the depositary institution may be either dark purple or black ink. Purple ink should be used when possible to facilitate better identification, but black ink is permitted to accommodate institutions with equipment providing only one source of ink. C. Collecting Institution Endorsement. i. Location. A collecting institution must place its endorsement on the back of the check within the three-inch space between the leading edge of the check and the space for the depositary institution s endorsement. Content. The collecting institution can only place the following information in the required area: 1. The institution s nine-digit routing number; 2. The endorsement date; and 3. An optional trace sequence number on the check. i Color. Collecting institutions may not use purple ink in their endorsement, since that color is for the exclusive use of depositary institutions. Collecting institutions can use black ink or any color other than purple. D. Returning Institution Endorsement. i. Location. The returning institution is prohibited from placing its endorsement in the areas reserved for the depositary institution and the payee. The returning institution cannot place its endorsement in the space between three inches from the leading edge of the check to the trailing edge of the check,

48 but may place its endorsement on the back of the check in the space provided for the collecting institution or anywhere on the face of the check. i iv. Content. There are no specific requirements or limitations for the content of the returning credit union s endorsement. Color. The returning institution is prohibited from using purple ink, but may use black ink or any color other than purple in its endorsement. Carbon Bands and Other Preprinted Information. The endorsement standard does not prohibit the use of a carbon band or other printed or written matter on the backs of checks and does not require institutions to avoid placing their endorsements in these areas. However, paying institutions that permit the use of carbon-band checks may have an increased risk of liability. 1. Checks may also bear preprinted information such as contracts and security agreements or lien information. All endorsers should arrange their endorsements so as to not interfere with the carbon band. Preprinted contracts and other information must be placed so as to not obscure the depositary and collecting institutions endorsement. v. Liability for Return Check Delays. The responsibility for loss resulting from a delay in the return of a check due to endorsements that are unreadable because of material on the back of the check is allocated to the institutions according to their endorsement responsibilities. vi. v vi Depositary Institution. The depositary institution is responsible for loss resulting from a delay in return caused by the condition of the check after its issuance until its acceptance by the depositary institution that made the endorsement illegible. Paying Institution. The paying institution is responsible for loss resulting from a delay in return caused by endorsements that are not readable because of other material on the back of the check at the time it was issued. Both depositary and paying institutions may shift these risks to their members or customers by agreement. E. Liability for Handling Checks. i. Liability for Payment. An institution that handles a check for forward collection or return is liable to any institution that later handles the check to the extent the subsequent institution does not receive payment for the check because of suspension of payments by another institution. If a returning credit union returned a check to an insolvent depositary institution and did not receive the full amount of the check from the failed institution, the returning credit union could obtain the unrecuperated amount from any institution prior to it in the collection-and-return chain of endorsement, including the paying institution. Because each institution in the collection-and-return chain could recover from a prior institution, any loss would fall on the first collecting institution that received the check from the depositary institution. i Recovery. When a check is returned through the same institutions used for the forward collection of the check, priority during the forward collection process controls over priority in the return process for determining prior and subsequent institutions. Notice. A credit union s handling a check for collection or return arises regardless of whether the credit union s endorsement appears on the check. A credit union s seeking recovery against a prior institution must send a notice to that prior institution promptly after it learns of facts entitling it to recovery. A written notice that reasonably identifies the check and the basis for recovery is sufficient if the check is not available. 21. PRESENTMENT AND ISSUANCE OF CHECKS. A. Payable-through and Payable-at Checks. A check payable at or through a paying institution is considered drawn on that institution. B. Receipt at Institution Office or Processing Center. A check is considered received by the paying institution when it is received: i. At a location to which delivery is requested by the paying institution; At an address of the institution associated with the routing number on the check;

49 i iv. At any branch or head office, if the institution is identified on the check by name without an address; or At a branch, head office, or other location consistent with the name and address of the institution on the check if the institution is identified on the check by name and address. C. Liability of Institution During Forward Collection. Settlements between institutions for the forward collection of a check are final when made. However, a collecting institution handling a check for forward collection may be liable to a prior collecting institution, including the depositary institution and the depositary institution s customer or member. D. Issuance of Payable-Through Checks. An institution that arranges for checks payable by it to be payable through another institution, must require that the following information is printed conspicuously on the face of each check: i. The name, location and first four digits of the nine-digit routing number of the institution by which the check is payable; and The words Payable Through, followed by the name of the payable-through institution. 22. VARIATION BY AGREEMENT. The effect of the provisions of Subpart C may be varied by agreement, except that no agreement may disclaim the responsibility of an institution for its own lack of good faith or failure to exercise ordinary care, or can limit the measure of damages for such lack of care or failure. The parties may agree upon the standards by which such responsibility is to be measured, provided the standards are not unreasonable. 23. LIABILITY. A. Standard of Care, Liability, Measure of Damages. All institutions must exercise ordinary care and act in good faith in complying with the regulatory requirements. An institution that fails to exercise ordinary care or act in good faith may be liable to the depositary institution, the depositary institution s member or customer, the owner of the check or another party to the check. The measure of damages for failure to exercise ordinary care is the amount of the loss incurred, up to the amount of the check, reduced by the amount of the loss the party would have incurred even if the institution had exercised ordinary care. B. Paying Institution s Liability. The standard of care and measure of damages described above does not affect a paying institution s liability for wrongful dishonor under UCC 4-402, which is different from the above standard of care and measure of damages. If a paying institution fails to make an expeditious return of a check, and fails to comply with the deadline for returns under the UCC and Regulation J with a single nonpayment of a check, it may be liable for failure to meet either standard (but not for both). C. Comparative Negligence. This may occur when the paying or returning institution delays in returning a check because neither can identify the depositary institution (when, for example, it fails to properly endorse a check). In these cases, the paying or returning institution s liability to the depositary institution would be reduced in proportion to the amount of negligence attributable to the each. D. Responsibility for Back of the Check. The paying institution and depositary institution share the responsibility for keeping the back of the check clear for endorsements during the forward collection and return process. i. The paying institution is responsible for the condition of the check when it is issued by it or its member/customer, such as the effect of the carbon band or preprinted endorsement placed on the back of the check before issuance. The paying institution may shift this responsibility by agreement. The depositary institution is responsible for the condition of the check after it is issued and before it is accepted by the depositary institution, as well as any condition of the check during the handling of the check. The depositary institution would be responsible for the adverse effect of a stamp placed on the check by its members of a prior endorser. The depositary institution may refuse to accept a check where the back is unreasonably obscured. 24. RELATION TO STATE LAW. The provisions of this regulation subpart supersede any inconsistent provisions of the UCC as adopted in any state, or of any state law, but only to the extent of the inconsistency. 25. GENERAL PROVISIONS REGARDING SUBSTITUTE CHECKS. A. Legal Equivalence. A substitute check for which a financial institution has provided the warranties described in Section is the legal equivalent of an original check, if the substitute check:

50 i. Accurately represents all of the information on the front and back of the original check as of the time the original check was truncated; and Bears the legend: This is a legal copy of your check. You can use it the same way you would use the original check. B. Reconverting Bank Duties. The Credit Union must ensure that a substitute check for which it is the reconverting bank : i. Bears all endorsements applied by parties that previously handled the check in any form for forward collection or return; i Identifies the reconverting bank in a manner that preserves any previous reconverting bank identifications (in accordance with generally applicable industry standards for substitute checks and Regulation CC); and Identifies the financial institution that truncated the original check. C. Applicable Law. A substitute check that is the legal equivalent of an original check will be subject to any provision of Regulation CC, the UCC, and any other applicable federal or state law that the original check would have been subject to, so long as such provision is not inconsistent with the Check 21 Act or Subpart D of Regulation CC. 26. SUBSTITUTE CHECK WARRANTIES. A. Content and Provision of Substitute Check Warranties. A financial institution that transfers, presents or returns a substitute check (or a paper or electronic representation of a substitute check) for which it receives consideration warrants the following to the parties identified: i. The substitute check meets the requirements for legal equivalence; and No depositary institution, drawee, drawer, or endorser will receive presentment or return of, or be charged for, the substitute check, the original check, or a paper or electronic representation of either such that that person will be asked to make a payment based on a check that it has already paid. B. Warranties Recipients. A financial institution makes the warranties to the person to which it transfers, presents or returns the substitute check (or any representation) and to any later recipient, which could include a collecting or returning institution, the depositary institution, the drawer, the payee, the depositor and any endorser. These parties receive the warranties regardless of whether they received the actual substitute check or a representation. 27. SUBSTITUTE CHECK INDEMNITY. A. Scope if Indemnity. An institution that transfers, presents or returns a substitute check (or any representation) for which it receives consideration must indemnify the recipient and any later recipient (including a collecting or returning institution, the depositary institution, the drawer, the drawee, the payee, the depositor and any endorser) for any loss incurred by any recipient of a substitute check if the loss occurred because of the receipt of the substitute check instead of the original check. B. Indemnity Amount. i. If the loss resulted from a breach of a substitute check warranty, the amount of the indemnity will be the amount of any loss including interest, costs, reasonable attorney s fees and other expenses of representation proximately caused by the warranty breach. i iv. If the loss did not result from a breach if a substitute check warranty, the amount of the indemnity will be the amount of any loss up to the amount of the substitute check, and interest and expenses including costs and reasonable and attorney s fees and other expenses of representation related to the substitute check. The indemnity amount will be reduced in proportion to the amount of negligence or bad faith attributable to the indemnified party. The indemnity provisions are intended to put the parties in the position in which they would have been had they received the original check rather than the substitute check. The indemnifying depositary institution may satisfy the indemnity by either paying the amount of the indemnity or by producing the original check or a copy of the original. If an indemnifying depositary institution produces the original check, it is only liable for losses that have been incurred up to the time the original check was provided to the indemnified party. By

51 providing the original check, a depositary institution may recover any funds already paid under the indemnity that exceeds the losses incurred up to the time of production. Although the provision of the original check will limit the indemnity a depositary institution must provide, it will not affect the institution s liability for breach of warranty. v. An indemnifying institution will be subrogated to the rights of the party that it indemnifies to the extent of the indemnity that was provided and may recover from another party based on a warranty or other claim. 28. EXPEDITED RE-CREDIT FOR CONSUMERS. A. Circumstances Giving Rise to a Claim. A consumer may make a claim for a re-credit with respect to a substitute check if the consumer asserts in good faith that: i. A financial institution improperly charged the consumer s account for a substitute check (although the consumer need not be in possession of that substitute check at the time he/she submits a claim); i The substitute check was not properly charged to the consumer s account or the consumer has a warranty claim with respect to the substitute check (the original or substitute check will be necessary); and The consumer has suffered a loss. B. Timing of Claim. A consumer must make a claim within 40 days from the later of the date the financial institution mailed or delivered the periodic statement that contains information about the transaction that gave rise to the claim, or the date the financial institution mailed or delivered the substitute check that gave rise to the claim. The time to submit the claim may be extended by the financial institution due to extenuating circumstances of the consumer. i. If a consumer makes a claim verbally and the financial institution requires the claim to be in writing, the consumer s claim is timely if the verbal claim is received within the 40-day time limit. C. Content of Claim. The consumer s claim must include the following information: i. A description of the claim, including the reason why the consumer s account was improperly charged for the substitute check or the nature of the warranty claim; i iv. A statement that the consumer suffered a loss and an estimate of the amount of the loss; The reason why the production of the original check or a sufficient copy is necessary to determine whether the charge to the consumer s account was proper or the consumer s warranty claim is valid; and Sufficient information to allow the financial institution to identify the substitute check and investigate the claim. v. If any information is missing, the consumer must be notified of the specific information that is missing. D. Submission of Claim. A financial institution that requires consumers to submit claims in writing: i. May permit consumers to submit written claims electronically; i Must inform consumers who submit verbal claims of the requirement that the claim be submitted in writing (at the time of the verbal claim), and may require consumers to submit the written claim within 10 business days after the banking day on which the financial institution receives the verbal claim; and Must compute the time periods for acting on consumer claims to begin on the banking day the financial institution receives the written claim. E. Action on Claims. i. Valid Claim. If a financial institution determines that a consumer s claim is valid, it must do the following: 1. Re-credit the consumer s account for the amount of the loss, up to the amount of the substitute check, plus dividends if the account is a dividend-bearing account, no later than

52 the end of the business day after the banking day on which the financial institution determines that the consumer s claim is valid; and 2. Send the consumer the C-22 Expedited Re-Credit Claim, Valid Claim Refund Notice. i Invalid Claim. If a financial institution determines that a consumer s claim is not valid, it must send the consumer the C-24 Expedited Re-Credit Claim, Denial Notice. Status of Claim Undetermined and Provisional Re-Credit. 1. If the financial institution has not made a determination as to the validity of the consumer s claim before the end of the 10th business day after the banking day on which the claim was received, the financial institution must do the following: a. By the end of that business day, re-credit the consumer s account of the amount of the loss, up to the lesser of the amount of the substitute check or $2,500, plus dividends on that amount if the account is a dividend-bearing account; and b. Send the consumer the C-23 Expedited Re-Credit Claim, Provisional Refund Notice. 2. If the consumer s claim is determined to be valid, the consumer s account will be recredited for the amount of the remaining amount of the loss, if any, up to the amount of the substitute check, plus dividends if the account is a dividend-bearing account, no later than the end of the 45th calendar day after the banking day on which the claim was received, and send the C-22 notice. iv. Reversal of Re-Credit. A financial institution may reverse a re-credit, plus dividends, that have been paid if the financial institution does the following: 1. Determines that the consumer s claim was not valid; and 2. Provides the proper notices to the consumer. F. Availability of Re-Credit. The amount of any re-credit must be made available for withdrawal from the consumer s account no later than the start of the business day after the banking day on which the re-credit was provided. i. The availability of a re-credit may be delayed until the start of the earlier of the business day after the banking day on which the financial institution determines the claim is valid or the 45th calendar day after the banking day on which the financial institution received the verbal or written claim, if: 1. The consumer submitted the claim within 30-calendar days after opening his or her account; 2. Not counting the transaction that gave rise to the re-credit claim; (1) on 6 or more business days within the 6-month period preceding the submission of the claim, the balance in the consumer s account was negative or would have become negative if checks or other charges had been paid, or (2) on two or more business days during the same six month period, the balance in the consumer s account was negative or would have become negative in the amount of $5,000 or more if checks or other charges had been paid; or 3. The financial institution has reasonable cause to believe that the claim is fraudulent. A financial institution that delays availability as provided in the above paragraph may not impose an overdraft fee with respect to drafts drawn by the consumer on re-credited funds until the fifth calendar day after the calendar day on which a C-22 or C-23 notice was provided to the consumer. G. Overdraft Fees. A financial institution may not impose an overdraft fee with respect to drafts drawn by the consumer on such re-credited funds until the 5th calendar day after the calendar day on which the financial institution sent the required notice. H. Notices Relating to Expedited Re-Credit Claims. i. Notices of Re-Credit. A financial institution that re-credits a consumer account must send notice to the consumer of the re-credit no later than the business day after the banking day on which the financial institution re-credits the consumer account. This notice must include the amount of the recredit and the date on which the re-credited funds will be available for withdrawal.

53 i Notice of Invalid Claim. A financial institution must send a notice (C-24 or similar notice) to the consumer no later than the business day after the banking day the institution determines that the consumer s claim is invalid because a substitute check was properly charged to the consumer s account or that the consumer s warranty claim for the substitute check is not valid. The notice shall also include the original check or a sufficient copy and shall demonstrate that the substitute check was properly charged to the consumer s account or that the warranty claim is not valid. Additionally, the notice must include information or documents the institution relied on in making its determination or a statement that the consumer may request copies of such documents or information. Notice of a Reversal of Re-Credit. A financial institution must send notice (C-25 or similar notice) no later than the business day after the banking day the institution reverses an amount it previously re-credited to a consumer account. The notice shall also include the amount of the reversal, including both the amount of the re-credit and the amount of dividends paid on the re-credited amount, and the date the reversal was made. I. Other Claims Not Affected. Providing a re-credit does not absolve the financial institution from liability for a claim made under any other provision of law, such as a claim for wrongful dishonor or any additional damages under Regulation CC or the UCC. 29. EXPEDITED RE-CREDIT FOR FINANCIAL INSTITUTIONS. A. Circumstances Giving Rise to a Claim. A financial institution that has an indemnity claim under Section with respect to a substitute check may make an expedited re-credit claim against an indemnifying institution if: i. The institution or another institution it has indemnified, has received a claim for expedited re-credit from a consumer or would have been subject to such a claim if the consumer account had been charged for the substitute check. i The institution is obligated to provide an expedited re-credit or has suffered a loss due to the substitute check. The production of the original check or a sufficient copy is necessary to determine the validity of the charge to the consumer account or the validity of the warranty claim connected with the substitute check. B. Procedures for Making Claims. A claimant financial institution must send its claim to the indemnifying institution so that it is received by the end of the 120th calendar day after the date of the transaction that gave rise to the claim. i. The claim must include the following information: 1. A description of the consumer s claim or the warranty claim related to the substitute check and the reason why the substitute check may not be properly charged to the consumer account; 2. A statement that the claimant institution is obligated to re-credit a consumer account or otherwise has suffered a loss and an estimate of the amount of the re-credit or loss, including dividends if applicable; 3. The reason why production of the original check or a sufficient copy is necessary; and 4. Additional information to allow the indemnifying institution to identify the substitute check and investigate the claim. i If a claimant institution submits a copy of a substitute check, the institution shall take reasonable steps to ensure that the copy cannot be mistaken for the actual substitute check. The indemnifying institution may require the claimant institution to submit the required information in writing and may permit the claimant institution to submit the written claim electronically. At the time a verbal claim is submitted, the indemnifying institution must inform the claimant institution of the requirement for a written claim. The 10 day time period for acting on a claim shall begin on the date the indemnifying institution receives the written claim. C. Action on Claims. Within 10 days after receiving a claim and all required information, the indemnifying institution must do the following:

54 i. Re-credit the claimant institution for the amount of the claim, up to the amount of the substitute check, plus dividends (if applicable); i Provide the claimant institution with the original check or a sufficient copy; or Provide information to the claimant institution regarding why the indemnifying institution is not obligated to comply with the above and provide a re-credit or provide the original check or a copy of the original check. D. Re-Credit and Other Liabilities. Providing a re-credit does not absolve the indemnifying institution from liability for claims brought under any other law or from damages under Sections and E. Indemnifying Institution s Right to a Refund. If a claimant institution reverses a re-credit previously made to a consumer account or receives reimbursement for a substitute check that formed the basis if its expedited re-credit claim, the claimant institution must provide a prompt refund to any indemnifying institution that advanced funds to the claimant. The amount of the refund shall be the amount of the reversal or reimbursement obtained by the claimant, up to the amount previously advanced by the indemnifying bank. 30. LIABILITY. A. Measure of Damages. i. The measure of damages for breach of a warranty is an amount equal to the sum of the amount of the loss suffered as a result of the breach, up to the amount of the substitute check, plus any dividends and expenses (including costs and reasonable attorney s fees and other expenses of representation) related to the substitute check. i The amount of damages received by a person is reduced by the amount received and retained as a recredit. If a person incurs damages that resulted in whole or in part from that person s negligence or failure to act in good faith, then the amount of any damages due that person (under comparative negligence) shall be reduced in proportion to the amount of negligence or bad faith attributable to that person. B. Timeliness of Action. Delay is excused if caused by interruption of communication or computer facilities, suspension of payments by another financial institution, war, emergency conditions, failure of equipment, or other circumstances beyond the control of the institution and if the institution uses such diligence as the circumstances require. C. Jurisdiction. A person may bring an action to enforce a claim in any United States district court or in any other court of competent jurisdiction. The statute of limitations for filing a lawsuit shall be one year from the date on which the person s cause of action accrued. A cause of action accrues as of the date on which the injured person first learns, or by which such person reasonably should have learned of the facts and circumstances giving rise to the cause of action. D. Notice of Claims. Unless a person gives notice of a claim to the warranting or indemnifying institution within 30 calendar days after the person has reason to know of both the claim and the identity of the warranting or indemnifying institution, the warranting or indemnifying institution is discharged from liability in an action to enforce a claim to the extent of any loss caused by the delay in giving notice of the claim. A timely re-credit claim by a consumer constitutes timely notice. 31. CONSUMER AWARENESS. A. General Disclosure Requirement and Content. Every financial institution shall provide a disclosure (such as the FRB s C-5A Substitute Check Policy Disclosure or one containing similar language) to each of its members/customers that describes the following: i. That a substitute check is the legal equivalent of an original check; and The consumer re-credit rights that apply when a consumer in good faith believes that a substitute check was not properly charged to his or her account. 32. DISTRIBUTION OF DISCLOSURE. A. Distribution of Disclosure. i. The Credit Union will provide the above disclosure whenever new accounts are opened.

55 i iv. The Credit Union will provide the above disclosure to members who receive paid original or substitute checks with periodic statements. Additionally, the Credit Union will provide the disclosure to members who request an original check or a copy of a check and instead receive a substitute check. The disclosure must be provided no later than the time the consumer receives the substitute check. The disclosure only needs to be provided to one account holder in a joint account. 33. MODE OF DELIVERY OF INFORMATION. The Credit Union may deliver any required notice, disclosure or other information including original checks, copies of checks and substitute checks by United States mail or other means (including electronically) by which the consumer has agreed to receive account information. 34. RELATION TO OTHER LAW. The Check 21 Act and Subpart D of Regulation CC supersede any provision of federal or state law, including the UCC that is inconsistent, but only to the extent of the inconsistency. 35. VARIATION BY AGREEMENT. No provision of this regulation may be varied by agreement of the parties, except that Section may be varied by agreement of the Credit Union. FAIR and ACCURATE CREDIT TRANSACTIONS ACT FACT ACT DISCLOSURE The Fair and Accurate Credit Transactions Act of 2003 was signed into law by President Bush on December 4, This law, which went into effect on December 1, 2004, made significant changes and additions to the Federal Fair Credit Reporting Act. The FACT Act enhances the ability of consumers to combat identity theft, increases the accuracy of consumer reports, and allows consumers to exercise greater control regarding the type and amount of marketing solicitations they receive. The FACT Act provides for free annual credit reports, increases the standard for the accuracy of the information furnished to credit reporting agencies, strengthens adverse action notices, and creates a right to a credit score from a credit reporting agency for a reasonable fee. The FACT Act also requires a lender or broker who is considering a home loan application to provide a credit score without a fee and adds certain rights for identity theft victims and measures intended to prevent identity theft, including a duty on creditors to take certain steps before granting credit when a fraud alert is contained in a credit file or accompanies a credit score. Section 217 of the FACT Act requires that if any financial institution (1) extends credit and regularly and in the ordinary course of business furnishes information to a nationwide consumer reporting agency, and (2) furnishes negative information to such an agency regarding credit extended to a member, the institution must provide in writing, a clear and conspicuous notice about furnishing negative information to the member. This written notice must be provided to the member prior to or not later than 30 days after furnishing the negative information to a nationwide consumer reporting agency. As a member, we would like you to be aware that under the FACT Act we may report information about your account to the credit bureaus when payments are late, missed or in default. If you have any questions, please call us at The FACT Act EXPANDS CONSUMER RIGHTS & CREDIT UNION DUTIES UNDER THE FAIR CREDIT REPORTING ACT. THE CREDIT UNION HAS NEW NOTICE REQUIREMENTS IN THE FOLLOWING INSTANCES: 1. CREDIT SCORING USED IN A RESIDENTIAL REAL ESTATE TRANSACTION. 2. NEGATIVE CREDIT INFORMATION FURNISHED TO CONSUMER REPORTING AGENCY. 3. RISK BASED PRICING USED IN ACTING ON LOAN APPLICATION. 4. TRANSACTION ON AN ACCOUNT PREVIOUSLY INACTIVE FOR MORE THAN 2 YEARS. CONSUMER PROTECTION PROCEDURES IN ADDITION TO THE ABOVE NOTICES, CERTAIN REQUIRED PROCEDURES MUST BE ADOPTED AND MAINTAINED. AFTER RECEIVING A NOTICE OF DISPUTE FROM THE MEMBER, THE CREDIT UNION MUST CONDUCT AN INVESTIGATION AND REPORT ITS FINDINGS TO THE MEMBER WITHIN 30 DAYS. IF THE INFORMATION FURNISHED WAS INACCURATE, THEN THE CREDIT UNION MUST CORRECT THE INFORMATION WITH EACH CONSUMER-REPORTING AGENCY WHICH RECEIVED THE INACCURATE INFORMATION. CREDIT REPORTING AGENCIES MUST INCLUDE FRAUD ALERTS AND ACTIVE DUTY ALERTS IN THEIR REPORTS, NOTING WHEN THE CONSUMER DOES NOT AUTHORIZE NEW CREDIT EXTENSIONS. IN SUCH CASES, CREDITORS ARE PROHIBITED FROM GRANTING NEW CREDIT EXCEPT UNDER THE SPECIFIC AUTHORIZATION PROVISIONS OF THE STATUTE. CREDIT UNIONS ARE PROHIBITED FROM CHANGING CREDIT CARD ADDRESSES OR ISSUING ADDITIONAL CREDIT CARDS WITHOUT COMPLYING WITH THE FACT ACT RULES TO VERIFY IDENTITY. WCU CREDIT UNION OVERDRAFT PRIVILEGE POLICY (A Discretionary Overdraft Service) It is WCU Credit Union s policy to utilize the JMFA OVERDRAFT PRIVILEGE program to manage members checking accounts and build good relationships with members using the service. However, when a member exceeds their privilege limit, our policy is not to permit further overdrafts. Under certain circumstances, because of technical problems or member relations, it may be necessary, or WCU Credit Union may choose to make an exception to this policy. The OPA (Overdraft Privilege Administrator) will have the authority and responsibility for approving all overdraft accounts exceeding $

56 The Overdraft Privilege Administrator will have authority and responsibility for approving all overdrafts exceeding the member s Overdraft Privilege limit up to $ WCU Credit Union will disclose and charge a fee of $35.00 per item paid into overdraft which is the same fee charged for items that are returned. It is our policy that these overdrafts must be covered within 32 days of the first occurrence of an overdraft or the privilege limits may be revoked. Members will be notified of such occurrences. The Board of Directors from time to time will set a cap on the total dollar amount of all overdrafts consistent with WCU Credit Union s ability to absorb losses; at present the limit established is $50, If total overdrafts exceed 60 % of this amount, WCU Credit Union will monitor total overdrafts on a daily basis. If total overdrafts exceed 80 % of this amount, WCU Credit Union will begin to limit total overdrafts to assure that total overdrafts do not exceed this limit. It is the policy of WCU Credit Union to allow employees to participate in the Overdraft Privilege program on the same basis as all other WCU Credit Union. Fees will be charged for these overdrafts as stated above for all WCU members. Upon each occurrence of an overdraft, WCU Credit Union will immediately notify the member by mail of the negative balance of the account and all fees assessed. The Overdraft Privilege Administrator will utilize periodic mail and/or telephone contact with the member in order to bring the account to a positive balance. All accounts that remain in a negative status will be charged off by the 45 th day or sooner if deemed to be uncollectible. WCU Credit Union will endeavor to identify heavy users, and contact them to see if they qualify for any other program or solution available. WCU Credit Union will counsel with willing heavy users on appropriate money management techniques that would avoid frequent overdrafts. Decisions to approve overdrafts which exceed the member s Overdraft Privilege limit shall not be made based on a prohibited basis (e.g., race, color, national origin, sex, marital status, or age). Approved by WCU Credit Union s Board of Directors on this the 18th day of April, WHAT YOU NEED TO KNOW ABOUT OVERDRAFTS AND OVERDRAFT FEES An overdraft occurs when you do not have enough money in your account to cover a transaction, but we pay it anyway. We can cover your overdrafts in two different ways: 1. We have standard overdraft practices that come with your account. 2. We also offer overdraft protection plans, such as a link to another account or a line of credit, which may be less costly than our standard overdraft practices. To learn more, ask us about these plans. This notice explains our standard overdraft practices. - What are the standard overdraft practices that come with my account? We do authorize and pay overdrafts for the following types of transactions: - Checks and other transactions made using your checking account number - Automatic bill payments We will not authorize and pay overdrafts for the following types of transactions without your consent. - ATM transactions - Everyday debit card transactions We pay overdrafts at our discretion, which means we do not guarantee that we will always authorize and pay any type of transaction. If we do not authorize and pay an overdraft, your transaction will be declined. - What fees will I be charged if WCU Credit Union pays my overdraft? Under our standard overdraft practices: - We will charge you a fee of up to $35 each time we pay an overdraft - There is no limit on the total fees we can charge you for overdrawing your account - What if I want WCU Credit Union to authorize and pay overdrafts on my ATM and everyday debit card transactions? If you want us to authorize and pay overdrafts on ATM and everyday debit card transactions, call (256) , visit our website at us at tholmes@wcucu.com, complete the form below and present it at a branch or mail it to: 2505 Hwy 31 S, Decatur, AL You can revoke your authorization for WCU Credit Union to pay these overdrafts at any time by any of the above methods. Your revocation must include both your name and your account number so that we can properly identify your account. I do not want WCU Credit Union to authorize and pay overdrafts on my ATM and everyday debit card transactions. I want WCU Credit Union to authorize and pay overdrafts on my ATM and everyday debit card transactions. Printed Name: Date: Account Number: Options for Covering Unexpected Overdrafts Dear Member,