Privacy Policy

                                                                 Your Financial Privacy at VNBTrust, N.A.
                                                                                            July 2009

In accordance with federal law, we are providing VNBTrust, N.A.’s privacy statement to you. VNBTrust is committed to respect and protect the confidentiality of our clients. Statutory requirements mean that our privacy statement will contain some standardized legalese. We are always happy to interpret if you ever have any questions.  Thank you and, as always, we appreciate your business.

At VNBTrust, we treat the confidentiality of our clients as a cardinal client expectation. When Congress enacted the Gramm-Leach-Bliley Act of 1999 (the “Financial Services Modernization Act”), it required banks and other providers of financial services and products to provide annual written notice of their privacy policies. Our commitment to confidentiality is not new. We will continue to respect and protect the privacy of the information you have entrusted to us. This notice provides you with information on how VNBTrust collects and uses your personal client information. This notice also details how we maintain the confidentiality and accuracy of certain information.

Information We May Collect

We may collect non-public personal information about you from any of the following sources:
          • You or your representative on applications, personal financial statements, or other oral,       written or electronic communications, such as your name, address, social security number, birth date, assets and income;
          • Transactional activity in your account (for example, trading history and balances);
          • Other interactions with VNBTrust (for example, discussions with our staff or information you provide in writing or electronically);
          • Information services and consumer reporting agencies (for example, to verify your identity, to assess your creditworthiness, or to better understand your product and service needs); and
          • Information we obtain from others to verify information provided by you, such as your employment history and credit or other relationships with third parties.
          • Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into VNBTrust).

Non-public personal information does not include information that is available from public sources, such as telephone directories or government records.

Information We Disclose

We do not disclose any non-public personal information about our clients or former clients to anyone outside of VNBTrust, except as required or permitted by law. For example, we may disclose information we collect about you to government entities in compliance with properly authorized investigations and in response to subpoenas. In addition, we may disclose information we collect as described above to companies that perform marketing services on our behalf (although to date no such companies have been engaged by VNBTrust) and to third parties to assist us in servicing your account with us. When we provide non-public personal information for these purposes, we require these providers to agree to safeguard your information and to use the information only for the intended purpose.

Disclosure Within the VNBTrust Corporate Family

VNBTrust, N.A. has two affiliates, Virginia National Bank (the parent corporation) and
VNB Investment Management Company, LLC (a wholly owned subsidiary of VNBTrust), that are considered to be within the VNBTrust “corporate family” because of common ownership or control. For future reference, you may wish to note that to the extent permitted by law, we may share information about our transactions with you, as well as your identification information, with our affiliates and other companies that in the future may become part of the VNBTrust “corporate family.” The law provides that we also could share with companies in our corporate family other information about you, including:
          • Information we obtain from your applications or other forms, such as your assets, income, and employment history;
          • Information we obtain from a consumer reporting agency, such as your creditworthiness and credit history; and
          • Information we obtain from others to verify information provided by you, such as your credit or other relationships with third parties.

Please note, however, that for VNBTrust and any other companies that in the future become part of the VNBTrust corporate family, we do not plan to share with them any application and credit-related information about you without first obtaining your consent or providing you with the right to opt out of the sharing of such information. To this end, we would provide to you instructions on how to exercise your right to opt out.

Accuracy of Client Information

We believe it is vitally important that the information we maintain about you is as accurate as possible. We maintain internal controls and procedures to ensure the accuracy of your information. Should you have a question or concern about the accuracy or completeness of your information, please contact us and we will take immediate steps to correct the information or amend our records.

Information Security

We endeavor to restrict access to non-public personal information about you to those employees who need such information to perform their job responsibilities. All VNBTrust personnel work pursuant to policies and a code of conduct that strongly emphasizes confidentiality. In addition, we maintain physical, electronic and procedural safeguards that comply with federal regulations and standards to guard your non-public personal information.

Former Clients

If you decide to close your account or should your relationship with us be terminated for some other reason, we will continue to treat and safeguard your information as described in this notice.