Fact Act and Identity Theft Red Flag Compliance

Endeavor Bank will combine, as appropriate, any existing policy and procedures to help detect, prevent, or mitigate identity theft. The Bank has a policy in place entitled Identity Theft-Red Flags and a program to help control reasonably foreseeable client risks from identity theft.

Red Flag Identification
As part of its implementation, Endeavor Bank has considered relevant identity theft risk factors related to various departments and subsidiaries. Only certain Endeavor Bank business units handle consumer information. Those business units and particular systems were evaluated for access to "identifiable information" and associated risks identified. Once identified, an assessment of risk mitigation and other actions was conducted in accordance with the program and any compliance issues reported. Additional sources of Red Flags will be considered on an ongoing basis and evaluated based on relevant risk factors to each business unit.

Detecting Red Flags
The program's policies and procedures address the detection of red flags in connection with systems or personnel handling "identifiable information." Once identified, that particular system or persons will be guided by the policies and procedures of the program or any other relevant Endeavor Bank  Information Security policy.

Preventing and Mitigating Identity Theft
The program's policies and procedures provide for appropriate responses to those Red Flags identified as having a high risk for affected business units. Where possible, prevention measures were developed and implemented as appropriate to help detect, prevent or mitigate possible risks of identity theft. Those actions taken to help detect, prevent or mitigate possible identity theft may include actions such as monitoring high-risk systems for identity theft, contacting affected clients involved in possible security incidents, changing passwords and limiting access to systems involved in security incidents, and notifying law enforcement, among others. In the event identity theft is confirmed, Endeavor Bank will notify affected clients as soon as feasible.

Monitoring the Program
On a regular basis, Endeavor Bank will review and update the program to reflect changes in risks to clients or to the safety and soundness of Endeavor Bank from identity theft. This may include changes in possible methods related to or in connection with detecting, preventing, or mitigating identity theft. Endeavor Bank will also update the program as appropriate if changes occur to the type of accounts it holds or if any business arrangements change the landscape of the compliance requirements.

Program Administration
The Administration of the program is conducted by Endeavor's Chief Operations Officer. The administration involves the continuation of current Information Security Program policies and procedures, reviewing and approving compliance reporting and any additional duties regarding the detection, prevention and mitigation of identity theft. Compliance with the Red Flag Program is reported annually to the Board of Directors of Endeavor Bank and any significant changes to the program will also be reported to that Board.