This Policy statement explains what American Bank and Trust Company does to keep information about you private and secure. We want you to know how we manage that information to serve you and that you have choices about how it is shared. We, our, and us, when used in this notice, means our family of companies, which are listed at the end of this Policy statement. Please carefully read this notice.

THE INFORMATION WE COLLECT

• We get information from your requests for our products and services. One example is your taxpayer identification number obtained for deposit account relationships; another example is income on loan applications.
• We get information about your transactions with us and with others. For example, we have your account balance information and electronic images of checks you issued that were presented to us for payment.
• We get information, such as your credit history, from consumer reporting agencies.

HOW WE SAFEGUARD YOUR INFORMATION

We take a number of steps to protect the privacy of information about you. Here are some examples:

• We keep information under physical, electronic or procedural controls that comply with or exceed governmental standards.
• We authorize our employees, agents and contractors to get information about you only when they need it to do their work for us.
• We train our employees to make sure they understand the importance of confidentiality and respect customer privacy.
• We require companies working for us to protect your information. They agree to use it only to provide the services we ask them to perform for us.

OUR USE OF YOUR INFORMATION

We may share information about you within our family as required or permitted by law. This helps us to offer you financial products and services, such as loans, deposits, investments, debit cards, credit cards, and insurance.

In order to provide our products and services, we may share any of the information we gather about you with agents and service providers to perform functions on our behalf under contractual service agreement, such as printing and distributing transaction notices and account statements via email and postal mail, analyzing data, providing marketing services, processing applications and credit card payments, and servicing accounts. These service providers have access to nonpublic information needed to perform their functions, but may not use it for other purposes.

We may also share information about you in other ways, as required or permitted by law. Example situations are: to protect against fraud, to answer a non-wage garnishment or tax levy notice, to respond to a subpoena, to service your account, to report to a credit bureau, and with your consent.

YOUR PRIVACY CHOICES

You have the right to choose how we share nonpublic information that identifies you. If you are in agreement with our Privacy Policy and our nonpublic information handling practices, you do not need to contact us.

We also offer you the following two additional choices about sharing information that identifies you. You have the option of selecting either or both choices:

Choice #1. Affiliate sharing: You may tell us not to share the following information about you within our family of companies:

• Information from your applications to be used to determine your eligibility, such as your income.
• Information from consumer credit reports, such as your credit history.
• Information from sources used to verify information you provide us, such as outstanding loans or employment history.

Even if you do tell us not to share, we may share other types of information within our family of companies. For example, we may share name and address, information about transactions or balances with us, as well as survey results.

Choice #2. Affiliate marketing: You may tell us to limit our family of companies, such as our holding company, financial services and mortgage affiliates, from marketing their products and services to you if you do not have an account or business relationship with them. These marketing offers are based on your personal information that our affiliate receives from a company within our family. This information includes your income, your account history with us and your credit history with us. Your choice to limit these marketing offers will apply for five years from when you tell us your choice. After five years, you will receive a renewal notice from us that will allow you to continue to limit our affiliate marketing. If you choose to limit affiliate marketing, your choice may not be effective until thirty days after we receive your instructions or October 1, 2008, whichever date is later.

INFORMING US ABOUT YOUR PRIVACY CHOICES

You can inform us by:

• calling us toll-free at 1-877-626-2265 and requesting to speak with a Relationship Specialist at any of our offices during regular weekday business hours from 9:00 a.m. to 5:00 p.m. Central Time. It is very helpful if you can provide your full name, residence address and home phone number when calling us about your privacy choices, or
• for hearing impaired assistance, dialing 7-1-1, then 1-877-626-2265 and wait for operator assistance to be subsequently connected to a Relationship Specialist at any of our offices during regular weekday business hours from 9:00 a.m. to 5:00 p.m. Central Time, or
• writing us to let us know if you select either Choice #1 or Choice #2, or both available choices. In addition to informing us of your choices, please include your full name, residence address and home phone number with your letter, and mail it to: CIF Administrator, American Bank and Trust Company, N.A., 4301 East 53^rd Street, Davenport, IA 52807-3861.

Each person may separately make privacy choices, and joint account holders may make privacy choices for each other. If only one joint account holder makes a privacy choice, information about the other joint account holder may be shared.

We provide our Policy to you when you open a new account. We also send it annually to current customers. We may change our Policy. We will send you a new policy if we broaden our information sharing practices about you.

SPECIAL NOTICE FOR VERMONT RESIDENTS

In order to comply with Vermont law, we will automatically treat accounts with Vermont mailing addresses as if you have made the privacy choices listed above.

SPECIAL NOTICE FOR CALIFORNIA RESIDENTS

In order to comply with California law, the following applies if your account has a California mailing address. We will not share information that we have about you with non-financial companies outside our family of companies, unless otherwise permitted by law. We will not share information about you within, or with financial companies outside our family of companies unless we first provide you with further privacy choices or unless otherwise permitted by law.

OUR FAMILY OF COMPANIES GOVERNED BY THIS POLICY

This Policy covers the AmBank Holdings, Inc. family of companies. The following is a list of its financial services companies:

• American Bank and Trust Company, N.A.
• AmBank Financial Services, Inc.
• ABC Mortgage Solutions d/b/a T.S. Financial, Inc.

This Policy applies to current and former consumer customers of our family of companies.

ELECTRONIC CONFIDENTIALITY SAFEGUARDS

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

E-mail Communications. Please be aware that using ordinary e-mail communications to originate a message to us is a form of insecure electronic communication. We will not be held liable for the possible inappropriate use of information sent by e-mail over the Internet. Due to unknown third-parties’ usual involvement in the routing and transmittal of ordinary unencrypted e-mail, our Privacy Policy shall not apply to the extent that e-mail passes beyond the electronic communications network we administer. Personal information (account numbers, identification numbers, etc.) considered to be confidential by a user of these electronic services should not be included in the unencrypted content of e-mails addressed to us. Usually First Class Mail, phone conversations with a known bank associate, or personal visits to our nearest office are better alternatives when communicating with us about sensitive matters. You can also use our encrypted Internet messaging service within our Online Banking suite to safely convey sensitive information and instructions to us.

Electronic Access Privacy. When you access our Online Banking services, a small file commonly referred to as a “cookie” may be stored on the electronic device you use when communicating with us through the Internet. Through an automatic monitoring program, we may keep track of how often visits are made to our Web Site and/or Online Banking services, the date and time of each visit, and the pages accessed within the visited domain site. Neither the cookie file nor the monitoring procedures provide us with any personal information about you.

Electronic Security. We assign a unique User ID and require the use of a Personal Identification Number (“PIN”) or password, which must be periodically changed by you, when permitting electronic access to your non-public information. You are expected to keep your PINs and passwords a secret to avoid compromising the security measures intended to prevent unauthorized information disclosures. We have instructed our personnel to never ask you for your PIN or password when providing service. Our service departments and third-party technical support vendors use a variety of electronic safeguards, such as electronic firewalls, to provide reasonable assurances concerning the integrity and security of all your non-public information.