Policies - Privacy Principles - Luxury Policy

At Regent Bank, the basis of each client relationship is trust. You have chosen to do business with Regent Bank, and we are obligated to honor that relationship with great care, beginning with the information you have chosen to share with us. We believe that your privacy should not be compromised. At the same time, we want to offer you the array of financial products and services you need to accomplish your financial goals.

Respect of Right to Privacy
We recognize your right to privacy at Regent Bank. We recognize that you have a right to expect your personal financial information to remain private and secure at all times.

Collection and Use of Personal Information
We collect, retain and use information about you only where we reasonably believe that it will help administer our business or provide products, services and other opportunities to you. We collect and retain information about you only for specific business purposes and we will tell you why we are collecting and retaining it upon your request. We use information to protect and administer your records, accounts and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand your financial needs so that we can provide you with quality products and superior service.

Maintenance of Accurate Information
We continually strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please notify us. We will investigate your concerns and correct any inaccuracies.

Limited Employee Access to Personal Information
At Regent Bank, employee access to personally identifiable client information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of client information and on these Privacy Principles. Because of the importance of these issues, all Regent Bank employees are responsible for maintaining the confidentiality of client information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Restrictions on the Disclosure of Account Information
Regent Bank is committed to the security of your financial and personal information. All our operational and data processing systems are in a secure environment that protects your account information from being accessed by third parties. We maintain and gain access to client information only in accordance with our internal security standards.

It is the Bank’s policy not to reveal specific information about client accounts or other personally identifiable data to unaffiliated third parties for their independent use, except for the exchange of information with reputable information reporting agencies to maximize the accuracy and security of such information or in the performance of bonafide corporate due diligence or business matters, unless 1) the information is provided to help complete a client-initiated transaction; 2) the client requests or permits it; 3) the disclosure is required by or allowed by law (e.g., subpoena, investigation of fraudulent activity, request by regulator, etc.) or 4) the client has been informed about the possibility of disclosure for marketing or similar purposes through a prior communication and given the opportunity to decline (i.e., "opt out").

Third-Party Disclosure Restrictions
When the Bank conducts business with third parties, it requires its vendors and suppliers to maintain similar standards of conduct regarding the privacy of personally identifiable client information provided to them.

Disclosure of Privacy Policies
Regent Bank recognizes and respects the privacy expectations of our clients. We want our clients to understand our commitment to privacy in our use of client information. As a result of our commitment, we have developed these Privacy Principles, which are made readily available to our clients. Clients who have a question about these Privacy Principles or have a question about the privacy of their client information should call us at 918.273.1227 or 800.503.5400 or email us at privacymanager@bankregent.com.

Regent Capital Corporation, Inc.

This policy statement fulfils the requirement placed upon Regent Capital Corporation, and Regent Bank (collectively, "Regent"), by the American Recovery and Reinvestment Act to adopt a company-wide "excessive or luxury expenditures policy" (the "Policy"). The Policy's purpose is two-fold. First, it prohibits any Regent officer, director, employee or agent from making any excessive expenditures on entertainment and events, office or facility renovations and aviation or other transportation services. Second, the Policy ensures that Regent's expenditures for conferences, staff development, performance incentives and similar activities are reasonable. The specific provisions of the Policy are as follows:

1. Entertainment:
   Regent requires that all entertainment expenses be incurred for legitimate business purposes. Occasional client-centered functions, such as sporting or community events, dining, hunting, golfing or other events involving reasonable travel, do not violate the Policy. All entertainment expenses must be documented accurately.

2. Renovations:
   Regent requires that all renovations of facilities and office spaces conform with an approved project plan, which must be consistent with Regent's current business and profitability plans. Exceptions to this provision are permissible only if a specific renovation projects relates to an emergency situation, such as an act of nature, and the expenditure is necessary to make the effected facility or office space operational. Renovations that would appear excessive or luxurious from the perspective of a reasonable shareholder are prohibited.

3. Conferences:
   Regent strongly encourages its staff to attend conferences that provide appropriate educational and client-development opportunities. However, Regent will not pay for an employee to attend any conferences unless the conference relates to the financial services industry and correlates to the individual employee's job responsibilities. Occasionally, it may be appropriate for an employee's spouse to accompany the employee to such conferences. Expenses of the employee's spouse will not be paid by the Bank.

4. Employee Recognition/Holiday Parties:
   Regent believes that employee-recognition events and holiday parties serve an important role in fostering a productive work environment and demonstrating appreciation to employees. These events should occur within Regent's general geographic area and should not be unreasonably expensive.

5. Board/Management Retreats:
   Regent's board of directors and/or officers may participate in company-sponsored retreats. Any such retreat should be used for educational or business planning purposes and should not involve unreasonable expenditures. Because appropriate planning is a vital part of Regent's business success, no part of this policy should limit or otherwise discourage a retreat focused on strategic planning or the education of the board of directors.

6. Transportation:
   Appropriate transportation is required for Regent's directors, officers, employees and agents to travel to bank locations and conferences, to pursue business development opportunities and to conduct merger and acquisition research. However, such transportation should be conducted in the most cost appropriate way, keeping in mind Regent's legitimate business needs. Private air services are not allowed without the approval of the chairman of the board of directors.

7. Administration:
   Strict adherence to the Policy is mandated for all Regent employees. Policy violations will be identified through periodic reviews. Any non-compliance must be promptly reported to the Audit Committee of the board and may result in disciplinary action against those accountable for policy adherence, up to and including termination of employment.

   Regent's chief financial officer ("CFO") is responsible for the Policy's day-to-day administration, while the chief executive officer ("CEO") is responsible for overall adherence to the Policy and must approve any exceptions. Following any approval of private air services by the chairman of the board of directors, the CFO and the CEO must certify that such approval was obtained. The CFO and CEO certifications must be maintained in the Company's corporate records.

The Policy and any amendments thereto must be posted on Regent's website. A copy of the Policy must be provided to the U.S. Department of the Treasury and the Federal Deposit Insurance Corporation.

The Board of Directors approved and adopted this policy on April 15, 2010