Marlborough Co-Operative Bank Privacy and Security Policy

This Agreement and Disclosure is made in compliance with federal law regulating electronic funds transfer (EFT) services. Electronic funds transfers are electronically initiated transfers of money involving a deposit account at the Marlborough Co-Operative Bank. The following disclosures set both your and our rights and responsibilities concerning the electronic funds transfer.

DESIGNATED ACCOUNTS FOR CARD USE
When you request an ATM or Debit MasterCard or Internet Banking with us, you choose the accounts for which you want to access. These are known as �designated� account(s). If any designated account is a joint account, all of the account holders must sign the application for the card. If you are requesting a Debit MasterCard, you must choose a checking account as one of your designated accounts. You may choose to access any of the following types of accounts: � Checking (NOW, Basic or Free Checking) � Statement Savings Account (cannot be used for debit purchase, POS transactions) � Statement Money Market (cannot be used for debit purchase, POS transactions).

ELECTRONIC FUNDS TRANSFERS INITIATED BY THIRD PARTIES
You may authorize a third party to initiate electronic funds transfers between your account and the third party�s account. These transfers to make or receive payment may be one-time occurrences or may occur as directed by you. These transfers may use the Automated Clearinghouse (ACH) or other payments network. Your authorization to the third party to make these transfers can occur in a number of ways. In some cases, your authorization can occur when the merchant posts a sign informing you of their policy. In all cases, the transaction will require you to provide the third party with your account number and bank information. This information can be found on your check or on your deposit slip. Thus, you should only provide your bank and account information (whether over the phone, the Internet or via some other method) to trusted third parties whom you have authorized to initiate these electronic funds transfers. Examples of these transfers include, but are not limited to: � Preauthorized credits: You may make arrangements for certain direct deposits (such as an employers, social security, V.A. & pension plans) to be accepted into your checking or savings account(s). � Preauthorized payments: You may make arrangements to pay certain recurring bills from your checking or savings account(s). � Electronic check conversion: You may provide your check to a merchant or service provider who will scan the check for the encoded bank and account information. The merchant or service provider will then use this information to convert the transaction into an electronic funds transfer. This may occur at the point of purchase or when you provide your check by other means such as by mail or drop box.

TEL-R-LINK TELEPHONE TRANSFERS
You may access your account by telephone 24 hours a day at 1-800-591-2757 using your personal identification number, a touch tone phone, your account numbers and the last four digits of your social security number, to: � transfer funds from checking to checking � transfer funds from checking to savings � transfer funds from statement savings account to checking � transfer funds from statement savings account to savings � make payments from checking to loan accounts with us � make payments from statement savings account to loan accounts with us � get information about: � the account balance of checking accounts � the last five deposits to checking accounts � the last five withdrawals from checking accounts � the account balance of savings accounts � the last five deposits to savings accounts � the last five withdrawals from savings accounts.

YOUR OPTION TO LIMIT CASH WITHDRAWALS
In addition to dollar amount limitations of withdrawals using your ATM Card and Debit MasterCard and/or code that we may establish, you have the option to limit the amount of cash that can be withdrawn by your ATM Card and Debit MasterCard to $50.00 per day or some other amount acceptable to us. ATM Transfers � types of transfers and dollar limitations � You may access your accounts(s) by ATM, using your ATM Card and personal identification number (PIN) to: � make deposits to checking account(s) � make deposits to statement savings account(s) � get cash withdrawals from checking account(s) � You may withdraw no more than $100.00 per day, per card, up to the available balance in your account. � For higher limits, inquire at our customer service department � get cash withdrawals from statement savings account(s) � You may withdraw no more than $100.00 per day, per card, up to the available balance in your account. � For higher limits, inquire at our customer service department � transfer funds from checking to statement savings account(s) � transfer funds from statement savings account to checking accounts(s) � get information about the account balance of your checking account(s) � get information about the account balance of your statement savings account(s) Some of these services may not be available at all ATM terminals.

TYPES OF DEBIT MASTERCARD TRANSACTIONS
� Debit MasterCard ATM Transactions � dollar limitations � You may access your checking and/or statement savings account(s) � You can not exceed $400.00 in transactions per day, per card � Debit MasterCard Point-of Sale Transactions � You may ONLY access your checking account(s) to purchase goods (in person, by phone, by internet), to pay for services, get cash from merchant, if the merchant permits or from a participating financial institution and do anything that you can do with a credit card (that a participating merchant will accept with a credit card) � You may not exceed $1,000.00 in transactions per day, per card.

CURRENCY CONVERSION
If you effect a transaction with your Debit MasterCard in a currency other than US Dollars, MasterCard International Incorporated will convert the charge into a US dollar amount. MasterCard International will use its currency conversion procedure, which is disclosed to institutions that issue MasterCard cards. Currently, the conversion rate used by MasterCard International to determine the transaction amount in US dollars for such transactions is generally either a government mandated rate or a wholesale rate determined by MasterCard International for the processing cycle in which the transaction is processed, increased by an adjustment factor established from time to time by MasterCard International. The currency conversion rate used by MasterCard International on the processing date may differ from the rate that would have been used on the purchase date or cardholder statement posting date.

ADVISORY AGAINST ILLEGAL USE
You agree not to use your card(s) for illegal gambling or other illegal purpose. Display of a payment card logo by, for example, an online merchant does not necessarily mean that transactions are lawful in all jurisdictions in which the cardholder may be located.

TERMINATING THIS AGREEMENT
� You can terminate this agreement at any time by notifying us in writing and no longer using your Card or PIN number at any machine � We can terminate this agreement at any time by notifying you in writing.

INTERNET BANKING COMPUTER TRANSFERS
Types of transfers - you may access your account(s) through the internet at www.bankatmcb.com and using your Access Number and Password to: � Transfer funds from checking to checking � Transfer funds from checking to savings � Transfer funds from savings to checking � Transfer funds from savings to savings � Make payments from checking to loan account(s) with us � Make payments from savings to loan account(s) with us � Get information about: � The account balance of checking account(s) � Account history � The account balance on savings account(s) � Account history � The loan account(s) balance � Loan history.

MINIMUM ACCOUNT BALANCE
� We do not require you to maintain a minimum balance in any account as a condition of using an access device (card or code) to accomplish a transfer.

FEES
� We do not charge for direct deposits to any type of account � We do not charge for electronic funds transfers � Please refer to our separate fee schedule for charges that may apply to your ATM/Debit MasterCard � When you use an ATM not owned by us, you may be charged a fee by the ATM operator or any network used (and you may be charged a fee for a balance inquiry even if you do not complete a funds transfer).

DOCUMENTATION
� Terminal transfers: You can get a receipt at the time you make any transfer to or from your account using one of our ATM machines or point-of-sale terminals � Preauthorized credits: If you have arranged to have direct deposits made to your account at least once every 60 days from the same person or company, you can call us at (508) 485-3000 to find out whether or not the deposit has been made � Periodic statements: You will get a monthly account statement from us for your Checking, Statement Savings account and Statement Money Market account(s).

PREAUTHORIZED PAYMENTS
� Right to stop payment and procedure for doing so: If you have told us in advance to make regular payments out of your account, you can stop any of these payments. Here is how: � Call us at (508) 485-3000 or write us at 175 Main Street - PO Box K � Marlborough, MA 01752 Your request must be received at the bank at least 3 business days or more before the payment is scheduled to be made. If you call, we may also require you to put your request in writing and get it to us within 14 days after you call. A fee for the stop-payment will be charged to your account. � Notice of varying amounts: If these payments may vary in amount, the person you are going to pay will tell you, 10 days before each payment, when it will be made and how much it will be. (You may choose instead to have that person notify you only if the amount differs). � Liability for failure to stop-payment of preauthorized transfer: If you order us to stop one of these payments 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.

ADDITIONAL INFORMATION REQUIRED BT MASSACHUSETTS LAW
� Any documentation provided to you which indicates that an electronic fund transfer was made to another person shall be admissible as evidence of the transfer and shall constitute prima-facie proof that the transfer was made. � The initiation by you of certain electronic fund transfers from your account will effectively eliminate your ability to stop-payment of the transfer.

UNLESS OTHERWISE PROVIDED IN THIS AGREEMENT, YOU (THE CONSUMER) MAY NOT STOP PAYMENT OF ELECTRONIC FUND TRANSFERS, THEREFORE YOU SHOULD NOT EMPLOY ELECTRONIC ACCESS FOR PURCHASES OR SERVICES UNLESS YOU ARE SATISFIED THAT YOU WILL NOT NEED TO STOP PAYMENT.

FINANCIAL INSTITUTION�S LIABILITY
If we do not complete a transfer to or from your account on time or in the correct amount according to our agreement with you, we will be liable for your losses or damages. However, there are some exceptions that we will not be liable for: � If, through no fault of ours, you do not have enough money in your account to make the transfer � If you have an overdraft line and the transfer would go over the credit limit � If the automated teller machine where you are making the transfer does not have enough cash � If the terminal or system was not working properly and you knew about the breakdown when you started the transfer � If circumstances beyond our control (such as fire or flood) prevent the transfer, despite reasonable precautions that we have taken � If the funds are subject to legal process or other encumbrance restricting such transfer � There may be other exceptions stated in our agreement with you.

CONFIDENTIALITY
In order that your privacy may be protected, we will not disclose any information about you or your account to any person, organization or agency except: � For certain routine disclosures necessary for the completion of a transfer � For verification of the existence and condition of your account for a credit bureau or merchant � To persons authorized by law in the course of their official duties � To our employees, auditors, service providers, attorneys or collection agents in the course of their duties � Pursuant to a court order or lawful subpoena � To the consumer reporting agency as defined in Chapter 93 of the Massachusetts General Laws � By the written authorization which shall automatically expire 45 days after our receipt of your authorization If an unauthorized disclosure has been made, we must inform you of the particulars of the disclosure within 3 days after we have discovered that an unauthorized disclosure has occurred.

UNAUTHORIZED TRANSFERS
� Generally: Tell us AT ONCE if you think your card and/or code has been lost, stolen or used without your permission. Telephoning is the best way, if any, of minimizing your possible losses. You can lose no more than $50 if you fail to give us notice of your lost or stolen card and/or code and your card and/or code is used without your permission. � Additional Limits on Liability for Debit MasterCard Card when used for point-of-sale transactions: You will not be liable for any unauthorized transactions using your Debit MasterCard card when used for point-of-sale transactions, if: � You can demonstrate that you have exercised reasonable care in safeguarding your card from risk of loss or theft � You have not reported to us two or more incidents of unauthorized use within the prior twelve-month period � Your account is in good standing If any of these conditions are not met, your liability is the lesser of $50 or the amount of money, property, labor or services obtained by the unauthorized use before notification to us. �Unauthorized Use� means the use of your card by a person, other than you, who does not have actual, implied or apparent authority for such use and from which you receive no benefit. This additional limitation on liability does not apply to PIN-based transactions or transactions not processed by MasterCard � Contact in event of unauthorized transfer: If you think your card and/or code has been lost or stolen or that someone has transferred or may transfer money from your account without your permission, call us immediately at (508) 485-3000 between the hours of 8:30a.m.and 4:00 p.m., Monday through Friday; or you may write us at 175 Main street, P.O. Box K, Marlborough, MA 01752.

PROTECTED CONSUMER USE
Chapter 167B of the Massachusetts General Laws was enacted to provide a means for financial institutions, businesses and consumers to conduct their business relations more conveniently. Transferring funds electronically will supplement the use of checks, credit and cash and will not replace these present methods of doing business. As a consumer, you should be aware of your rights if you choose to utilize this system. � Prohibition of compulsory use. No person may: � Require you to use a preauthorized electronic fund transfer as a condition of the extension of credit unless the credit is being extended in connection with an overdraft checking plan or is being extended to maintain a specified balance in your account � Require you either to accept a transfer service or to establish an account which is accessed electronically as conditions of employment or receipt of governmental benefit � Require you to pay electronically for the purchase of good or services. If your account is to be credited by a preauthorized transfer you may choose the financial institution to which the transfer may be made. If the institution is technically capable of receiving such preauthorized transfer � Waiver of rights.: No writing or agreement signed by you can waive the rights conferred to you by Chapter 167B of the Massachusetts General Laws unless you decide to waive these rights in settlement of a dispute or action � Refunds. If it is the policy of a store or retail business to give cash refunds in return for an item purchased by cash, then this policy must also cover refunds for items purchased by electronic fund transfer unless it is clearly disclosed at the time the transaction is consummated that no cash or credit refunds are given for payments made by electronic fund transfers � Suspension of obligations. If a person agrees to accept payment by means of an electronic fund transfer and the system malfunctions preventing such a transfer, then the consumer�s obligation is suspended until the transfer can be completed, unless that person, in writing, demands payment by other means. � Prohibited means of identification. Your Social Security number cannot be used as the primary identification number although it can be used as secondary aid to identify you � Criminal liability. Procuring or using a card, code or other means of electronic access to an account with the intent to defraud is a basis for criminal liability.

ERROR RESOLUTION NOTICE
In case of Errors of Questions About Your Electronic Transfers, Telephone or Write us as soon as you can, if you think your statement, passbook or receipt is wrong or if you need more information about a transfer listed on the statement, passbook or receipt. We must hear from you no later than 60 days after we sent you the FIRST statement on which the problem or error appeared or if the only transfer possible is a direct deposit to your passbook account, no later than 60 days after the problem or error was FIRST reflected in your passbook or statement � Tell us your name and account number (if any) � Describe the error or the transfer you are unsure about and explain as clearly as you can why you believe it is 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 with 10 business days. We will determine whether an error occurred with 10 calendar days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to 45 calendar days to investigate your complaint or question. If we decide to do this, we will credit your account with 10 calendar 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 10 business days, we may not credit your account.

We will tell you the results within three business days after completing our investigation. If we decide that there was no error, we will send you a written explanation.

You may inspect or ask for copies of the documents that we used in our investigation. If there is no error, we may impose on you a reasonable charge for making such reproductions.

Please contact us at:
Marlborough Co-Operative Bank
Operations Department
175 Main Street
P.O. Box 175
Marlborough, MA 01752
(508) 485-3000 Ext.224
www.bankatmcb.com
Monday through Friday
8:30 a.m. to 4:00 p.m.

Privacy and Security Policy

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Electronic Funds Transfer
Your Rights and Responsibilities

Privacy and Security Policy

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Electronic Funds TransferYour Rights and Responsibilities

Electronic Funds Transfer
Your Rights and Responsibilities