Electronic Funds Transfer Disclosure

Regulation E
This disclosure contains information about terms, fees, and interest rates for some of the accounts we offer.

Electronic Funds Transfer Agreement and Disclosures 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 financial institution. The following disclosures set forth your and our rights and responsibilities concerning the electronic funds transfers. In this Agreement, the words "you" and "your" mean those who sign as applicants or any authorized user(s). The words "we", "us", and "our" mean the financial institution. The abbreviation "PIN" or word "code" means a personal identification number.

ATM, Point of Banking (POB), and Point of Sale (POS)
Brief Description: Statement Savings or Personal Checking account with electronic accessibility.

Types of Transfers: You may use the Automated Teller Machine (ATM) card and personal identification number (PIN) issued to you to initiate transactions at ATMs of ours, ATMs within the networks identified on your card and such other facilities as we may designate from time to time. Unless you specify a different account during automated teller machine (ATM) transactions, your Primary Account will be used for your transactions. Your Primary Account number and information may be obtained from the ATM Request Form. At present you may use your card to (some of these services may not be available at all ATMs):

Account Access:

• Withdraw cash from your checking account.
• Withdraw cash from your savings account.
• Transfer funds between your checking and savings accounts.
• Obtain balance information on your deposit accounts.
• Deposits are accepted only at Point of Banking locations.

Electronic Check Conversion: You may authorize a merchant or other payee to make a onetime electronic payment from your checking account using information from your check to:

i. Pay for purchases.
ii. Pay bills.

Limitations on Frequency and Amount:

• You may make 3 cash withdrawals from ATMs per day.
• You may withdraw up to a maximum of $500.00 (if there are sufficient funds in your account) per day.
• For security purposes, there are limits on the frequency and amount of transfers you may make at ATMs.
• Maximum withdrawal at ATMs is $500.00 per transaction. Point of Sale transactions may be made at stores and supermarkets equipped with Point of Sale terminals.

Fees and Charges for ATM Transactions:

• There is no charge for ATM withdrawals at machines owned by us.
• There is a $1.50 charge for each ATM withdrawal at machines we do not own.
• There is a Replacement Card Fee of $5.00 per card
• A $10.00 fee is charged for a check returned that was deposited to your account.

ATM Fees: When you use an ATM not owned by us, you may be charged a fee by the ATM operator (and you may be charged a fee for a balance inquiry even if you do not complete a fund transfer).

Electronic Funds Transfer

Types of Preauthorized Transfers: you may arrange for us to complete the following preauthorized transfers to your deposit accounts:

Accept direct deposits from the U.S. Treasury Department to your checking or savings account.

Limitations on Frequency and Amount:

No limitations on frequency or amount of transfers from checking accounts, but savings withdrawals are limited to six (6) transfers each four (4) week or similar period.

Fees and Charges:

Insufficient funds for electronic transactions - $25.00

We will charge $15.00 for each stop-payment order for preauthorized transfers

Point of Sale

Brief description: Use your Personal Checking account ATM card to make purchases at selected merchants.

Types of Transactions: You may use the card and PIN issued to you to pay for purchases from merchants who have agreed to accept the card at Point of Sale (POS) terminals within the networks identified on your card and such other terminals as the Savings Bank may designate from time to time. Point of Sale (POS) transactions will be deducted from your Primary Account. Point of Sale (POS) transactions involving a refund will be credited to your Primary Account. Your Primary Account number and information may be obtained from the POS Request Form.

Limitations on Frequency and Amount:

You may purchase up to a maximum of $2,500.00 worth of goods and services per day, exclusive of ATM withdrawals.

Fees and Charges:

We do not charge for any POS transaction.

24-Hour TeleBanker 315-339-0000

Main Menu push 1, Account Inquiry Menu push 2, Rate Inquiry push 3

Brief Description: Our 24-hour TeleBanker (315-339-0000) will give the current Savings and Certificate of Deposit RATE and ANNUAL PERCENTAGE YIELD (APY). This service will allow you to have access to your savings, checking, certificates of deposit, and loan accounts.

Types of Audio Response Services: You may access your deposit accounts by using a separate personal identification number (PIN) assigned to you and your account number in our audio response system. At the present time you may use the system to:

• Transfer funds between your deposit accounts.
• Obtain balance information on your deposit accounts.
• Verify the last date and amount of your payroll deposit.
• Determine if a particular check has cleared your account.

Limitations on Frequency and Amount:

You are limited to the following number of inquiries, transfers, or withdrawals: You may make six (6) transfers from your savings account each four (4) week or similar period. Transfers from your checking account are unlimited. Balance inquiries to your account are unlimited.

There is no limit on the amount of any transfer or withdrawal from the funds in your deposit accounts.

Fees and Charges for Audio Response Transactions:

We do not charge for any Audio Response transactions.

In addition to the limitations set forth above, the following limitations may be applicable to your accounts:

Liability for Unauthorized Transfers: Tell us AT ONCE if you believe your card, ATM PIN, POS card or PIN, or Audio Response PIN has been lost or stolen or if you believe that an electronic fund transfer has been made without your permission using information from your check. Telephoning is the best way of keeping your possible losses down. You could lose all the money in your account (plus your maximum overdraft line of credit). If you tell us within two (2) business days, you can lose no more than $50.00 if someone used your card or code without your permission. If you do NOT tell us within two (2) business days after you learn of the loss or theft of your card or code, and we can prove that we could have stopped someone from using your card or code without your permission if you had told us, you could lose as much as $500.00. Also, if your statement shows transfers that you did not make, including those made by card, code or other means, tell us at once. If you do not tell us within sixty (60) days after the statement was mailed to you, you may not get back any money lost after the sixty (60) days if we can prove that we could have stopped someone from taking the money if you had told us in time. If a good reason (such as a long trip or a hospital stay) kept you from telling us, we will extend the time periods.

MasterCard Debit Card Purchase Transactions: You will have no liability on purchase transactions without the use of a PIN if you:

i. Carefully safeguarded the Card from the risk of loss or theft and
ii. Have not made more than one claim of unauthorized use of the MasterCard Debit Card during the immediately preceding twelve-month period and
iii. Maintain your account in good standing with us. If any of these conditions are not met, your liability is limited to a maximum of $50.

Contact in the Event of Unauthorized Transfer:

If you believe your Card or Code has been lost or stolen, call 315-336-7300 or write: Rome Savings Bank, 100 W. Dominick Street, Rome, New York 13442-0311.

You should also call the number or write to the address listed above if you believe a transfer has been made using the information from your check without your permission.

Business days: For purposes of these electronic funds transfer disclosures, our business days are Monday through Friday. Saturday will carry forward to the first business day of the following week. Holidays are not included.

Documentation

Periodic Statement: You will get a monthly account statement from us, unless there are no transactions in a particular month. In any case, you will get a statement quarterly. You will get a quarterly statement from us on your savings account if this is the only account you maintain and the only possible electronic transfer to or from the account is a preauthorized deposit. If you have a passbook account, you may bring your passbook to us and we will record any direct deposits that we made to your account since the last time you brought in your passbook.

Terminal Receipt: You can get a receipt at the time you make any transfer to or from your account using one of our ATMs or purchase at a POS terminal.

Direct Deposits: If you have arranged to have direct deposits made to your account at least once every sixty (60) days from the same person or company, you can call us at 315-339-0000 to find out whether or not the deposit has been made.

Our Liability for Failure to make Transfers: 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:

• If, through no fault of ours, you do not have enough money in your account to make the transfer.
• If the money in your account is subject to legal process or other claim restricting such transfer.
• If the transfer would go over the credit limit on your overdraft line.
• If the ATM where you are making the transfer does not have enough cash.
• If the terminal or system was not working properly and you know about the breakdown when you started the transfer.
• If circumstances beyond our control (such as fire or flood) prevent the transaction, despite reasonable precautions that we have taken.

In case of errors or questions about your electronic transfers: Telephone us at 315-336-7300 or write us at ROME SAVINGS BANK, 100 West Dominick Street, Rome, NY 13442-0311 as soon as you can, if you think your statement or receipt is wrong or if you need more information about a transfer listed on the statement or receipt. We must hear from you no later than sixty (60) days after we sent the FIRST statement on which the problem or error appeared.

• 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 you complaint or question in writing within ten (10) business days.

We will determine whether an error has occurred within ten (10) business days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to forty five (45) days to investigate your complaint or question. If we decide to do this, we will credit your account within ten (10) business 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 ten (10) business days, we may not credit your account.

If a notice of error involves an electronic fund transfer that occurred within thirty (30) days after the first deposit to the account was made, the error involves a new account. For errors involving new accounts, point of sale debit transactions, or foreign-initiated transactions, we may take up to ninety (90) days to investigate your complaint or question. For new accounts, we may take up to twenty (20) business days to credit your account for the amount you think is in error.

We will tell you the results within three (3) business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.

Confidentiality: We will disclose information to third parties about your account or the transfers you make:

• To complete transfers as necessary
• To verify the existence and condition of your account upon the request of a third party, such as a credit bureau or merchant
• To comply with government agency or court orders
• If you give us your written permission

Personal Identification Number (PIN): The ATM PIN, POS PIN or Audio Response PIN issued to you is for your security purposes. The numbers are confidential and should not be disclosed to third parties or recorded on the card. You are responsible for safekeeping your PIN(s). You agree not to disclose or otherwise make your ATM PIN, POS PIN or Audio Response PIN available to anyone not authorized to sign on your accounts.

Notices: All notices from us will be effective when we have mailed them or delivered them to your last known address on our records. Notices from you will be effective when received by us at the telephone number or the address specified in this Agreement. We reserve the right to change the terms and conditions upon which this service is offered. We will mail notice to you at least twenty one (21) days before the effective date of any change, as required by law. Use of this service is subject to existing regulations governing your account and any future changes to those regulations.

Enforcement: In the event either party brings a legal action to enforce this Agreement or collect amounts owing as a result of any account transaction, the prevailing party shall be entitled to reasonable attorneys' fees and costs, including fees on any appeal, subject to any limits under applicable law.

Termination of ATM, POS, and Audio Response Services: You agree that we may terminate this Agreement and the use of your ATM card, POS, or Audio Response services, if:

• You or any authorized user of your ATM PIN, POS Card or PIN, or Audio Response PIN breach this or any other agreement with us.
• We have reason to believe that there has been an unauthorized use of your ATM PIN, POS Card or PIN, or Audio Response PIN.
• We notify you or any other party to your account that we have cancelled or will cancel this agreement.
• You or any other party to your account can terminate this agreement by notifying us in writing.

Termination of service will be effective the first business day following receipt of your written notice. Termination of this Agreement will not affect the rights and responsibilities of the parties under this Agreement for transactions initiated before termination.

Preauthorized Electronic Fund Transfers

Stop Payment Rights: If you have told us in advance to make regular electronic fund transfers out of your account(s), you can stop any of these payments. Here's how: Call us or write to us at the telephone number or address set forth above, in time for us to receive your request three (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 fourteen (14) days after you call. We will charge you $15.00 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, ten (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 Transfers: If you order us to stop one of these payments three (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.

Other Provisions: There may be a delay between the time a deposit is made and when it will be available for withdrawal. You should review our Funds Availability Policy to determine the availability of the funds deposited at ATMs. We reserve the right to refuse any transaction that would draw upon insufficient funds, exceed a credit limit, lower an account below a required balance, or otherwise require us to increase our required reserve on the account.

Currency Conversion: If you effect a transaction with your MasterMoney card in a currency other than US Dollars, MasterCard International 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 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. ATM Safety Tips

As issuers of Automated Teller Machine (ATM) access devices, we have provided for your information a list of safety precautions regarding the use of automated teller machines. Please read the following safety tips:

• Be aware of your surroundings, particularly at night.
• Your activity at the ATM facility is recorded by a surveillance camera or cameras.
• If the ATM facility has a door, make sure it is closed before beginning your transaction and after you complete your transaction.
• If another person is uncomfortably close to you, ask the person to step back before you complete your transaction.
• Refrain from displaying your cash at the ATM. As soon as your transaction is completed, place your money in your purse or wallet.Count the cash later in the safety of your car or home.
• If you have any complaints regarding the security of the ATM, please direct your complaints to Security Officer, Rome Savings Bank at (315) 336-7300 or to New York Department of Banking at (212) 618-6550. You should use the nearest public telephone to call the police if emergency assistance is needed.