Disclosures

Cash Reward/Kasasa® Cash Disclosure

Qualification Information: To earn your rewards, the following enrollments must be in place and all transactions and activities must post and settle to your Kasasa Cash account during each Monthly Qualification Cycle:

• At least one or more direct deposit, ACH payment, or bill pay transaction(s)

• At least 12 debit card purchases

• Be enrolled in and have agreed to receive e-statements rather than paper statements

Account transactions and activities may take one or more days to post and settle to the account and all must do so during the Monthly Qualification Cycle in order to qualify for the account’s rewards. The following activities do not count toward earning account rewards: ATM-processed transactions, transfers between accounts, debit card purchases processed by merchants and received by our credit union as ATM transactions, non-retail payment transactions and purchases made with debit cards not issued by our credit union. Transactions bundled together by merchants and received by our institution as a single transaction count as a single transaction for the purpose of earning account rewards.

“Monthly Qualification Cycle” means the current statement cycle.

Reward Information:

• When your Kasasa Cash account qualifications are met during a Monthly Qualification Cycle average daily balances up to and including $10,000 in your Kasasa Cash account earn a dividend rate of 1.98% resulting in an APY of 2.00%; and average daily balances over $10,000 earn a dividend rate of .2497% on the portion of the average daily balance over $10,000, resulting in a range from 2.00% to .41% APY depending on the account’s average daily balance.

• You will receive reimbursements up to $25 for nationwide ATM withdrawal fees incurred within your Kasasa Cash account during the Monthly Qualification Cycle in which you qualified.

• When Kasasa Cash qualifications are not met, ATM withdrawal fees are not refunded and the dividend rate earned on the entire average daily balance in the account will be .05% resulting in an APY of .05%;

• Dividends will be credited to your Kasasa Cash account on the last day of the current statement cycle.

• Nationwide ATM withdrawal fee reimbursements will be credited to your account on the first processing day of the following statement cycle.

• APY = Annual Percentage Yield. APY calculations are based on an assumed balance of $10,000 + $100,000 in your Kasasa Cash account and an assumed statement cycle of thirty-one (31) days.Rates, rewards, and bonuses, if any, are variable and may change after account is opened without notice to you. No minimum balance is required to earn or receive the account’s rewards. Rewards less than a penny cannot be distributed. Fees may reduce earnings.

Additional Information:

• Membership restrictions may apply.

• Account approval, conditions, qualifications, limits, timeframes, enrollments, log-ons and other requirements apply.

• No minimum deposit is required to open the account.

• Monthly Direct Deposit/ACH credit, enrollment in eStatements, and 12 debit card transactions are a condition(s) of this account.

• Enrollment in electronic services (e.g. online banking, e-statements) and log-ons may be required to meet some of the account’s qualifications.

• Limit of 1 account per owner/SSN.

• There are no recurring monthly maintenance charges or fees to open or close this account.

• Contact one of our credit union service representatives for additional information, details, restrictions, reward calculations, processing limitations, cycle dates and enrollment instructions.

• Federally insured by NCUA.

Trademarks:
Kasasa and Kasasa Cash are trademarks of Kasasa, Ltd., registered in the U.S.A.

Cash Bank Reward/Kasasa® Cash Back Disclosure

Qualification Information: To earn your rewards, the following enrollments must be in place and all transactions and activities must post and settle to your Kasasa Cash Back account during each Monthly Qualification Cycle:

• At least one or more direct deposit, ACH payment, or bill pay transaction(s)

• At least 12 debit card purchases

• Be enrolled in and have agreed to receive e-statements rather than paper statements

Account transactions and activities may take one or more days to post and settle to the account and all must do so during the Monthly Qualification Cycle in order to qualify for the account’s rewards. The following activities do not count toward earning account rewards: ATM-processed transactions, transfers between accounts, debit card purchases processed by merchants and received by our credit union as ATM transactions, non-retail payment transactions and purchases made with debit cards not issued by our credit union. Transactions bundled together by merchants and received by our institution as a single transaction count as a single transaction for the purpose of earning account rewards.

“Monthly Qualification Cycle” means the current statement cycle.

Reward Information:

• When Kasasa Cash Back qualifications are met during a Monthly Qualification Cycle, you will receive 4% cash back on up to a total of $200.00 debit card purchases that post and settle to the account during that cycle period. A maximum of $8.00 cash back payments may be earned per Monthly Qualification Cycle.?

• You will receive reimbursements up to $25.00 for nationwide ATM withdrawal fees incurred within your Kasasa Cash Back account during the Monthly Qualification Cycle in which you qualified.

• When your Kasasa Cash Back account qualifications are not met, no cash back payments are made and ATM withdrawal fees are not refunded.

• Cash back payments and nationwide ATM withdrawal fee reimbursements will be credited to your Kasasa Cash Back account on the first processing day of the following statement cycle.

• Rates, rewards, and bonuses, if any, are variable and may change after account is opened without notice to you. No minimum balance is required to earn or receive the account’s rewards. Rewards less than a penny cannot be distributed.

Additional Information:

• Membership restrictions may apply.

• Account approval, conditions, qualifications, limits, timeframes, enrollments, log-ons and other requirements apply.

• No minimum deposit is required to open the account.

• Monthly Direct Deposit/ACH credit, enrollment in eStatements, and 12 debit card transactions are a condition of this account(s).

• Enrollment in electronic services (e.g. online banking, e-statements) and log-ons may be required to meet some of the account’s qualifications.

• Limit of 1 account(s) per owner/SSN.

• There are no recurring monthly maintenance charges or fees to open or close this account.

• Contact one of our credit union service representatives for additional information, details, restrictions, reward calculations, processing limitations, cycle dates and enrollment instructions.

• Federally Insured by NCUA.

Trademarks:
Kasasa and Kasasa Cash Back are trademarks of Kasasa, Ltd., registered in the U.S.A.

Reward/Kasasa® Saver Disclosure

Account Overview:

Kasasa Saver: Linked with a Kasasa Cash, or Kasasa Cash Back account, this is a free, variable rate deposit account with no minimum balance that rewards accountholders with dividends when they meet the minimum qualifications associated with their linked account during that account's Monthly Qualification Cycle. In addition, the (a) dividends, (b) cash back dollars, (c) the nationwide ATM withdrawal fee refunds earned through the linked checking account are transferred into the Kasasa Saver account at the end of the cycle period to help the consumer save.

Dividend Rate & Annual Percentage Yield (APY)

• Compounding & Crediting:
  Dividends will be compounded on a monthly basis. Dividends will be credited to your Kasasa Saver account on the last day of the current statement cycle. If you close your account before the dividends are credited, you will not receive the accrued dividends. Dividends begin(s) to accrue on the business day you deposit noncash items (for example, checks).
  "Business Day" means a calendar day other than a Saturday or a Sunday, January 1, the third Monday in January, the third Monday in February, the last Monday in May, July 4, the first Monday in September, the second Monday in October, November 11, the fourth Thursday in November, or December 25. If January 1, July 4, November 11, or December 25 falls on a Sunday, the next Monday is not a Business Day.
  "Statement Cycle" means the period of time for which Franklin First Federal Credit Union provides a summary of the financial activities and transactions that post and settle to the accountholder's account.

• Balance Computation Method:
  We use the average daily balance method to calculate the dividends on your Kasasa Saver account. This method applies a periodic rate to the average daily balance in the account for the period. The average daily balance is calculated by adding the principal in the account for each day of the period and dividing that figure by the number of days in the period. The period we use is the Statement Cycle.

• Dividend Rate & Annual Percentage Yield:
  The dividend rate and Annual Percentage Yield (APY) associated with your Kasasa Saver account when linked to either a Kasasa Cash, or Kasasa Cash Back account is documented below. Please refer to the appropriate Kasasa Cash, or Kasasa Cash Back Truth In Savings Disclosure for specific account qualification information.
  When your linked Kasasa Cash, or Kasasa Cash Back qualifications are met during a Monthly Qualification Cycle:
  Kasasa Saver: average daily balances up to and including $25,000.00 in your Kasasa Saver account earn a dividend rate of .5486% resulting in an APY of .55% and average daily balances over $25,000.00 earn a dividend rate of .2497% on the portion of the average daily balance over $25,000.00, resulting in a range from .55%  to .31% APY depending on the Kasasa Saver account's average daily balance.
  When your linked Kasasa Cash, or Kasasa Cash Back qualifications are not met during a Monthly Qualification Cycle: the entire average daily balance in the Kasasa Saver account earns .05% APY.
  Dividends will be credited to your Kasasa Saver account on the last day of the current statement cycle.
  
  Kasasa Cash When Linked To Kasasa Saver: When linked to Kasasa Saver and your Kasasa Cash account's qualifications are met during a Monthly Qualification Cycle, average daily balances up to and including $10,000.00 in your Kasasa Cash account earn a dividend rate of 1.98% resulting in a non-compounding APY* of 2.00%; and average daily balances over $10,000.00 earn a dividend rate of .2497% on the portion of the average daily balance over $10,000.00, resulting in a non-compounding range from 2.00% to .41% APY depending on the account's average daily balance.
  
  When your linked Kasasa Cash account's qualifications are not met during a Monthly Qualification Cycle: ATM withdrawal fees are not refunded and the entire average daily balance in the account earns a dividend rate of .05% resulting in a non-compounding APY of .05%. Dividends will be credited to your Kasasa Cash account on the last day of the current statement cycle.
  
  * Dividends in Kasasa Cash do not compound because it is automatically transferred to the Kasasa Saver account within one day. Note: Automatic transfer may cause an overdraft to your Kasasa Cash account, if the account's balance is less than the transferred amount when transfer occurs.

APY = Annual Percentage Yield. APY calculations are based on an assumed balance of $10,000.00 + $100,000 in your Kasasa Cash account and 25,000.00+ $100,000 in your Kasasa Saver account and an assumed statement cycle of thirty-one (31) days. Rates, rewards, and bonuses, if any, are variable and may change after account is opened without notice to you. No minimum balance is required to earn or receive the account's rewards. Rewards less than a penny cannot be distributed. Fees may reduce earnings. You will automatically qualify for the account's rewards during your account's first statement cycle. If the account is closed before rewards are credited, you will forfeit the rewards.

Reward Distribution:

Kasasa Cash Back When Linked To Kasasa Saver: The cash back payments and nationwide ATM withdrawal fee reimbursements earned in your Kasasa Cash Back account will be credited to your Kasasa Saver account on first processing day of the following statement cycle.

Additional Information:

Account approval, conditions, qualifications, limits, timeframes, enrollments, log-ons and other requirements apply. Qualifications and rewards may vary by account. No minimum deposit is required to open the account. Monthly Direct Deposit/ACH credit/Bill Pay, eStatements may be a condition(s) of Monthly Kasasa Saver's linked Kasasa Cash, or Kasasa Cash Back account(s). See accompanying Fee Schedule for fees that may apply to this account. Enrollment in electronic services (e.g. online banking, e-statements) and log-ons may be required to meet some of of Kasasa Saver's linked Kasasa Cash, or Kasasa Cash Back account(s). Limit of one account(s) per Owner/SSN. There are no recurring monthly maintenance charges or fees to open or close this account. This account is not to be used for commercial purposes. If the account is closed, you will forfeit any rewards that have not been credited to your account. If, for whatever reason the Kasasa Saver portion of your account is closed, your account will automatically be converted to the associated standalone Kasasa Cash, or Kasasa Cash Back account and that account's terms and conditions articulated within their specific disclosure will apply.

Linked Accounts: You must have a linked Kasasa Cash, or a linked Kasasa Cash Back account in order to open a Kasasa Saver account, and the linked Kasasa Cash, or Kasasa Cash Back account must remain open throughout the period that you hold the Kasasa Saver account. A linked Kasasa Saver account is required for automatic savings.

Account Limitations: If Kasasa Saver Is Established As A Savings Account: Transfers or withdrawals from a Kasasa Saver account to (a) another account of the same depositor at our institution or to (b) a third party or an account of the same depositor at another bank, if made by preauthorized transfer, automatic transfer, telephone, fax or internet banking service and (c) transfers or withdrawals to a third party or to an account of the depositor to another account at another bank made by check, draft, debit card are limited to an aggregate total of six (6) per calendar month. There is no limit to the number of transfers or withdrawals from your Kasasa Saver account to repay loans at our institution or are made in person, by mail, by messenger or at an ATM. These transactions are considered made on the date the transaction posts and settles to your account, not the date the withdrawal request was initiated.

Contact one of our credit union service representatives for additional information, details, restrictions, reward calculations, processing limitations, cycle dates and enrollment instructions. Federally insured by NCUA Your Savings Insured To $250,000 Per Account. Kasasa, Kasasa Cash, Kasasa Cash Back, and Kasasa Saver are trademarks of Kasasa, Ltd., registered in the U.S.A.

Electronic Funds Transfers Disclosure - Internet Privacy & Security Statement

Online Banking User Agreement

ELECTRONIC FUNDS TRANSFERS -- YOUR RIGHTS AND RESPONSIBILITIES

Indicated below are types of Electronic Fund Transfers we are capable of handling, some of which may not apply to your account. Please read this disclosure carefully because it tells you your rights and obligations for the transactions listed. You should keep this notice for future reference. There are a number of ways in which you may access your account and perform deposits, withdrawals and transfers from your accounts, but you must be aware of Federal Regulations that limit the number of transactions in your savings/share accounts (not checking). Please see "Why a 6 Transfer Limit?" at the end of this disclosure.

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 recur as directed by you. These transfers may use the Automated Clearing House (ACH) or other payment networks. 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 credit union information. This information can be found on your check or draft as well as on a deposit or withdrawal slip. Thus, you should only provide your credit union 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 include, but are not limited to:

• Preauthorized payments: You may make arrangements to pay certain recurring bills from your checking or savings account(s).

• Electronic check or draft conversion - types of transfers - You may provide your check or draft to a merchant or service provider who will scan the check or draft for the encoded credit union 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 or draft by other means such as by mail or drop box.

• Electronic returned check or draft charge: Some merchants or service providers will initiate an electronic funds transfer to collect a charge in the event a check or draft is returned for insufficient funds.

Voice Response Telephone Transfers: You may access your account by telephone 24 hours a day toll-free at (866) 695-4393. Use your personal identification number, a touch tone phone, and your account numbers to:

• transfer funds from checking to savings

• transfer funds from savings to checking

• transfer funds from savings to savings

• transfer funds from Home Equity line of credit to checking

• make payments from checking to loan accounts with us

• make payments from savings to loan accounts with us

• get information about the account balance of checking and savings accounts

Your Option to Limit Cash Withdrawals: In addition to dollar amount limitations for withdrawals using your ATM Card and Check Card 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 or Check Card and/or code to $50.00 per day, or some other amount acceptable to us. ATM Transfers types of transfers, dollar limitations, and charges: You may access your account(s) by ATM using your ATM Card and personal identification number or Check Card (debit card) and personal identification number to:

• make deposits to checking account

• make deposits to savings account

• transfer funds between checking and savings account(s) with an ATM or debit card

• get information about the account balance of your checking or savings account(s)

• get cash withdrawals from checking account(s)

• you may withdraw no more than $200.00 per day

• At ATMs not owned by Franklin First there will be 6 free transactions per month. Each transaction after the first 6 will incur a $1.50 charge by us.

• At most MoneyPass network ATMs there will be no surcharge. All other ATMs not owned by Franklin First will charge a surcharge (a fee charged by the institution that owns the ATM).

Types of Check Card Point-of-Sale Transactions: You may access your checking account(s) to purchase goods (in person or by phone), pay for services (in person or by phone), get cash from a merchant, if the merchant permits, or from a participating financial institution, and do anything that can be done with a credit card (that a participating merchant will accept). Point-of-Sale Transactions - frequency and dollar limitations - Using your card:

• you may make no more than 20 transactions per day

• you may not exceed $2,000.00 in outstanding transactions per day

Currency Conversion: If you effect a transaction with your Check Card at a merchant that settles in currency other than US dollars, MasterCard will be convert the charge into the US dollar amount. The MasterCard currency conversion procedure includes use of either a government-mandated exchange rate, or a wholesale exchange rate selected by MasterCard. The exchange rate MasterCard uses will be a rate in effect on the date the transaction is processed. This rate may differ from the rate in effect on the transaction date or posting date. Advisory Against Illegal Use: You agree not to use your card(s) for illegal gambling or other illegal purposes. 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.

In the event that a new Check Card is issued to you for reasons such as, but not limited to, expiration, fraud, a change in your account status, our third party Check Card processor may communicate through MasterCard to merchants that you have relationships with to update your cardholder account-on-file information.

Franklin First Online Banking: You may access your account(s) by computer by logging onto our website at www.FranklinFirst.org. Click onto the Home Banking tab and enter your user identification and your password to:

• transfer funds from checking to savings

• transfer funds from savings to checking

• transfer funds from savings to share savings

• make payments from checking to loan accounts with us

• make payments from checking to third parties

• get information about the account balance of checking and savings account(s)

Mobile Wallets: A wallet provider, Apple or Samsung, provides a payment platform through which Cardholders can perform secure transactions. Network organizations and Elan, Franklin First’s debit card servicer, help facilitate the authorization and transmission of the secure transaction. The transaction is secured by replacing the cardholder’s physical card and personal account number (PAN) with a random digital number (also known as a ‘Token’) for use at a point-of-sale device or on another enabled device to execute transactions. Franklin First is the not the provider of the Wallet, and we are not responsible for providing the Wallet service to you. We are only responsible for supplying information securely to the Wallet provider to allow usage of the Franklin First card in the Wallet. We are not responsible or any failure of the Wallet, or the inability to use the Wallet for any transaction. We are not responsible for the performance or non-performance of the Wallet provider or any other third parties regarding any agreement you enter into with the Wallet provider or associated third party relationships that may impact your use of the Wallet. Please refer to the Mobile Wallet’s Terms and Conditions for more information.

Remote Deposit Capture (RDC): RDC is the ability to deposit a negotiable item (paper check) into a bank account from a remote location, such as an office or home, without having to physically deliver the check to the bank. This is typically accomplished by scanning a digital image of a check with an electronic device then transmitting that image to the bank for deposit. Please refer to the RDC Online Deposits Disclosure and Agreement for more information.

Termination: You may terminate the electronic fund transfer agreement by written notice to us. We may terminate the electronic fund transfer agreement by written notice to you.

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 preauthorized payments from any type of account.

ATM Operator/Network Fees: 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 fund transfer). You are allowed 6 free transactions per month on an ATM not owned by us. After 6 there is a $1.50 fee for each transaction. When you use a Franklin First ATM, withdrawals, transfers and inquiries are unlimited, with no fee.

DOCUMENTATION:

• Terminal transfers: You can get a receipt at the time you make any transfer to or from your account using one of our automated teller machines or at a point-of-sale terminal.

• 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 413-774-6700 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 accounts.

  • You will get a monthly account statement from us for your savings accounts, unless there are no electronic transfers in a particular month. In that case, you will get a statement at least quarterly.

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 or write us at the telephone number or address listed herein in time for us to receive your request 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.

• Please refer to our separate fee schedule for the amount we will charge for each stop payment order you give.

• Notice of varying amounts. If these regular 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 get this notice only when the payment would differ by more than a certain amount from the previous payment, or when the amount would fall outside certain limits that you set.)

• 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 to the extent of that one payment only.

ADDITIONAL INFORMATION REQUIRED BY MASSACHUSETTS LAW

1. 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.

2. 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. We will not be liable, for instance:

1. If, through no fault of ours, you do not have enough money in your account to make the transfer.

2. If you have an overdraft line and the transfer would go over the credit limit.

3. If the terminal or system was not working properly and you knew about the breakdown when you started the transfer.

4. If circumstances beyond our control (such as fire or flood) prevent the transfer, despite reasonable precautions that we have taken.

5. If the funds are subject to legal process or other encumbrance restricting such transfer.

6. 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:

1. for certain routine disclosures necessary for the completion of a transfer; or

2. for verification of the existence and condition of your account for a credit bureau or merchant; or

3. to persons authorized by law in the course of their official duties; or

4. to employees, auditors, service providers, attorneys or collection agents in the course of their duties; or

5. pursuant to a court order or lawful subpoena; or

6. to a consumer reporting agency as defined in Chapter 93 of Massachusetts General Laws; or

7. as explained in the separate Privacy Disclosure.

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

Consumer liability: 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 give us notice within 2 business days of your suspected lost or stolen card, and your card is used without your permission.

Additional Limit on Liability for your Check Card: Unless you have been grossly negligent or have engaged in fraud, you will not be liable for any unauthorized transactions using your lost or stolen Check Card. This additional limit on liability does not apply to ATM transactions, or to transactions using your Personal Identification Number. 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 at 413-774-6700, or write us at 57 Newton Street, Greenfield, MA 01301.

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.

1. Prohibition of compulsory use: No person may:

   1. 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,

   2. or require you either to accept a transfer service or to establish an account which is accessed electronically as a condition of employment or receipt of governmental benefits, or

   3. require you to pay electronically for the purchase of goods 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.

2. 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.

3. 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.

4. 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.

5. Prohibited means of identification: Your Social Security number cannot be used as the primary identification number although it can be used as a secondary aid to identify you.

6. 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 or Questions About Your Electronic Transfers, Telephone us at 413-774-6700, or write us at 57 Newton Street, Greenfield, MA 01301 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 send you the FIRST statement on which the problem or error appeared.

Contents of your notice must include:

1. Your name, account number and address.

2. 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.

3. 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 within 10 business days.

We will determine whether an error occurred within 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 within 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 our research or making those copies.

Mobile Access (also referred to as Mobile Finance Manager/MFM) is inclusive of the terms and conditions of the Electronic Funds Transfer Disclosure including but not limited to transaction limits, transaction processing and system availability.

Mobile Banking Requirements & Limitations

• Your mobile device must be on the list of supported devices (see "Information" in Mobile Banking Site)

• All bill payment payees must be established within Online Banking before payments can be made to the payee via Mobile Banking.

• You will not be able to access all functions/services that are accessible via Online Banking. Examples include, but are not limited to, electronic statement, check reordering, third party account transfer, and account aggregation services.

• The account balances presented to you in Mobile Banking are not necessarily your current balances. If you attempt to make a payment or transfer to be executed immediately, your current balance will be obtained to ensure that you have proper funds for the payment or transfer.

See below for Federal regulations.

Why a 6-transfer limit?

How Regulation D and E Affect You

Why is there a six transaction limit on my Share Savings Account?

The Federal Reserve, whose rules all financial institutions including Federal Credit Unions must follow, limits monthly transactions for accounts that are classified as Savings Accounts. Your Share Savings Account, qualifies as a 'Savings Account,' and is subject to a monthly six transaction limit imposed by the Federal Reserve rule known as Regulation D.

What transactions are limited to six (6) per month by Regulation D?

These transactions, using your Share Savings account are restricted and, will not be allowed after a total of six (6) occurrences have been reached per month:

• Online and Mobile Banking transactions

• Touch-Tone Teller Phone transactions

• Transfers for overdraft coverage from savings to a Share Draft Checking account.

• Transactions requested by telephone or fax.

• Transactions conducted by automatic, pre-authorized, or scheduled transfer to another institution or creditor.

What transactions are not affected by Regulation D, and are unlimited?

• Transactions conducted in-person in our branch.

• Transactions conducted by automated teller machine (ATM).

• Transactions mailed to or dropped into the night deposit box at 57 Newton St

• Transfers to pay any Franklin First loan or line of credit.

But this does not affect my Share Draft Checking Account?

No. Regulation D transaction limits do not affect your Share Draft Checking Account, which means that using debit/check cards for withdrawals is a definite advantage over numerous ATM withdrawals.

If a Share Savings Account used for overdraft protection transfers has reached its Regulation D limit, will overdraft transfers be honored?

No. If your Share Savings Account is used as a source for Share Draft Checking Account overdrafts, and if it has reached the 6-transaction limit for Regulation D, then overdraft transfers from your Share Savings Account will not be done. Transfers will then be attempted from your other overdraft sources, if available.

What are my options once an account has reached its Regulation D limit?

You may complete withdrawals and transfers in person, by mail, or using an ATM.

I have authorized a merchant to automatically withdraw payments from my Share Savings Account; Do these payments count against my monthly limit?

Yes. These payments (which you might know as "ACH" or "EFT" transactions) are affected by Regulation D limitations. Any withdrawals attempted beyond your monthly limit will not be honored and you will receive a notice by mail and incur an Insufficient Funds charge. To avoid this situation, make automatic payments using your Share Draft Checking Account or consider using Online Bill Pay to automatically send payments.

Home Equity Line of Credit Plan Disclosure

IMPORTANT TERMS OF OUR HOME EQUITY LINE OF CREDIT PLAN

This disclosure contains important information about our Home Equity Line of Credit Plan. You should read it carefully and keep a copy for your records.

AVAILABILITY OF TERMS: All of the terms described below are subject to change. If these terms change (other than the annual percentage rate) and you decide, as a result, not to enter into an agreement with us, you are entitled to a refund of any fees that you pay to us or anyone else in connection with your application.

SECURITY INTEREST: We will take a security interest in your home. You could lose your home if you do not meet the obligations in your agreement with US.

POSSIBLE ACTIONS: We can terminate your line, require you to pay us the entire outstanding balance in one payment, and charge you certain fees, if (1) you engage in fraud or material misrepresentation in connection with the plan; (2) you do not meet the repayment terms of this plan, or (3) your action or inaction adversely affects the collateral or our rights in the collateral.

We can refuse to make additional extensions of credit or reduce your credit limit if (1) any reasons mentioned above exist; (2) the value of the dwelling securing the line declines significantly below its appraised value for purposes of the line; (3) we reasonably believe that you will not be able to meet the repayment requirements due to a material change in your financial circumstances; (4) you are in default of a material obligation of the agreement;
(5) government action prevents us from imposing the annual percentage rate provided for in the agreement; (6) the priority of our security interest is adversely affected by government action to the extent that the value of the security interest is less than 120 percent of the credit line; (7) a regulatory agency has notified us that continued advances would constitute an unsafe and unsound business practice, or (8) the maximum annual percentage rate is reached.

TAX DEDUCTIBILITY: You should consult a tax advisor regarding the deductibility of interest and charges for the plan.

MINIMUM PAYMENT REQUIREMENTS: We offer 2 different payment options
(Option 1 = Standard; Option 2 = Home Improvement). Unless otherwise specified, the language within this disclosure applies to both options. The payment option that applies to your plan will be determined at closing. For all payment options you may obtain advances for a certain number of years. This period is called the "draw period". At our option we may renew or extend the draw period. After the draw period ends the repayment period will begin. You will be required to make monthly payments during both the draw and repayment periods. Your payment will include any amounts past due and any amount by which you have exceeded your credit limit, and all other charges.

OPTION 1: The draw period is 5 years. The length of the repayment period will depend upon the balance at the end of the draw period but it will never exceed 15 years. During the draw period your payment will be 1% of the outstanding balance each month or $100.00, whichever is greater. If the interest rate increases you will be required to make more payments. We will round the payment up to the next highest dollar.

After the draw period ends the repayment period will begin. At the beginning of the repayment period we will recalculate your payment to pay off the outstanding balance over 180 monthly payments. Your payment will be rounded up to the nearest dollar. Your payment will remain the same throughout the entire repayment period. The minimum payment may not repay the outstanding balance by the end of the repayment period. You will then be required to make a single balloon payment at the maturity date. Unless otherwise required by applicable law, we are under no obligation to refinance the balloon payment at that time. You may be required to make payments out of other assets you own or find a lender, which may be us, willing to lend you the money. If you refinance the balloon with us, you may have to pay some or all of the closing costs. Your payment will include any amounts past due and any amount by which you have exceeded your credit limit, and all other charges. Your payment will never be less than the smaller of $100.00, or the full amount that you owe.

NEGATIVE AMORTIZATION: Under some circumstances your payment may not cover the finance charges (interest) that accrue and "negative amortization" will occur. Negative amortization will increase the amount that you owe us and reduce the equity in your home.

OPTION 2 (HOME IMPROVEMENT): The draw period is 2 years. The length of the repayment period will depend upon the balance at the end of the draw period but it will never exceed 5 years. During the draw period your payment will be 1.5% of the outstanding balance each month or $100.00, whichever is greater.
If the interest rate increases you will be required to make more payments. We will round the payment up to the next highest dollar.

After the draw period ends the repayment period will begin. At the beginning of the repayment period we will recalculate your payment to pay off the outstanding balance over 60 monthly payments. Your payment will be rounded up to the nearest dollar. Your payment will remain the same throughout the entire repayment period. The minimum payment may not repay the outstanding balance by the end of the repayment period. You will then be required to make a single balloon payment at the maturity date. Unless otherwise required by applicable law, we are under no obligation to refinance the balloon payment at that time. You may be required to make payments out of other assets you own or find a lender, which may be us, willing to lend you the money. If you refinance the balloon with us, you may have to pay some or all of the closing costs. Your payment will include any amounts past due and any amount by which you have exceeded your credit limit, and all other charges. Your payment will never be less than the smaller of $100.00, or the full amount that you owe.

MINIMUM PAYMENT EXAMPLES:

OPTION 1 - If you made only the minimum monthly payment and took no other credit advances it would take 10 years 8 months to pay off a credit advance of $10,000 at an ANNUAL PERCENTAGE RATE of 4.75%. During that period, you would make 60 payments of $100.00, followed by 67 payments of $100.00 and one (1) final payment of $57.40.

OPTION 2 - If you made only the minimum monthly payment and took no other credit advances it would take 7 years to pay off a credit advance of $10,000 at an ANNUAL PERCENTAGE RATE of 6.0%. During that period, you would make 24 payments of $119.00 to $150.00, followed by 59 payments of $152.00 and one (1) final payment of $132.87.

REFUNDABILITY OF FEES: If you decide not to enter into this plan within three business days of receiving this disclosure and the home equity brochure, you are entitled to a refund of any fee you may have already paid.

TRANSACTION REQUIREMENTS: The minimum credit advance that you can receive is $5,000.00 for the first advance.

FEES AND CHARGES: You must pay certain fees to third parties to open the plan. These fees generally total between $0.00 and $300.00. If you ask, we will provide you with an itemization of the fees you will have to pay third parties.

FEES REIMBURSEMENT: Lender may pay bona-fide third party fees on Borrower's your behalf. If Lender does, Borrower may have to keep the plan open for a minimum of three years or be liable to reimburse Lender for the bona-fide third party fees. Any amounts owed may be added onto the principal balance.

PROPERTY INSURANCE: You must carry insurance on the property that secures this plan. If the property is located in a Special Flood Hazard Area we will require you to obtain flood insurance if it is available.

VARIABLE RATE FEATURE: This plan has a variable rate feature and the annual percentage rate (corresponding to the periodic rate) may increase requiring you to make more payments during the plan and the amount of a balloon payment, if any, will increase. The annual percentage rate includes only interest and no other costs. The annual percentage rate is based on the value of an index. The index is the Prime Rate published in the Money Rates column of the Wall Street Journal. When a range of rates has been published the highest rate will be used. We will use the most recent index value available to us as of the last day of the month preceding each rate adjustment.

To determine the annual percentage rate that will apply to your account, we add a margin to the value of the Index. The initial annual percentage rate may be "discounted" - it may not be based on the index and margin used for later rate adjustments. Any initial rate will be in effect for no more than 12 months. Ask us for the current index value, margin, discount availability and annual percentage rate. After you open a plan, rate information will be provided on periodic statements that we send you.

RATE CHANGES: The annual percentage rate can change monthly on the first day of your billing cycle. There is no limit on the amount by which the annual percentage rate can change during any one year period. The maximum ANNUAL PERCENTAGE RATE that can apply is 15% or the maximum permitted by law, whichever is less.

A minimum annual percentage rate will apply to this plan, commonly referred to as a 'Floor". If you choose Payment Option 1, under no circumstances will your ANNUAL PERCENTAGE RATE go below 3.25% at any time during the term of this plan, except when an initial discount feature applies. If you choose Payment Option 2, under no circumstances will your ANNUAL PERCENTAGE RATE go below 6.00% at any time during the term of this plan, except when an initial discount feature applies. Ask us for the specific rate limitations that will apply to your credit line.

MAXIMUM RATE AND PAYMENT EXAMPLES:

OPTION 1 - If you had an outstanding balance of $10,000 during the draw period, the minimum payment at the maximum ANNUAL PERCENTAGE RATE of 15% would be $100.00. This annual percentage rate could be reached at the time of the 13th payment during the draw period. If you had an outstanding balance of $10,000 during the repayment period, the minimum payment at the maximum ANNUAL PERCENTAGE RATE of 15% would be $141.00. This annual percentage rate could be reached at the time of the 1st payment during the repayment period.

OPTION 2 - If you had an outstanding balance of $10,000 during the draw period, the minimum payment at the maximum ANNUAL PERCENTAGE RATE of 15% would be $150.00. This annual percentage rate could be reached at the time of the 13th payment. If you had an outstanding balance of $10,000 during the repayment period, the minimum payment at the maximum ANNUAL PERCENTAGE RATE of 15% would be $238.00. This annual percentage rate could be reached at the time of the 1st payment.

ADDITIONAL HOME EQUITY PLANS: Please ask us about our other available home equity line of credit plans.

HISTORICAL EXAMPLE: The following table shows how the annual percentage rate and the minimum payments for a single $10,000 credit advance would have changed based on changes in the index over the past 15 years. The index values are from the last business day of January of each year.

While only one payment per year is shown, payments may have varied during each year. The table assumes that no additional credit advances were taken, that only the minimum payments were made, and that the rate remained constant during each year. It does not necessarily indicate how the index or your payments will change in the future.

Wall Street Journal Prime Rate Index Table