Texas Policies and Procedures Designed to Detect and Prevent Insider Trading

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US-TC1012
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This Policy Statement implements procedures to deter the misuse of material, nonpublic information in securities transactions. The Policy Statement applies to securities trading and information handling by directors, officers and employees of the company (including spouses, minor children and adult members of their households).

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FAQ

No Insider may give trading advice of any kind about the Company to anyone, whether or not such Insider is aware of material nonpublic information about the Company. No Insider may trade in any interest or position relating to the future price of Company Securities, such as a put, call or short sale.

SEC Tracking Market surveillance activities: This is one of the most important ways of identifying insider trading. The SEC uses sophisticated tools to detect illegal insider trading, especially around the time of important events such as earnings reports and key corporate developments. 5.

No Insider may give trading advice of any kind about the Company to anyone, whether or not such Insider is aware of material nonpublic information about the Company. No Insider may trade in any interest or position relating to the future price of Company Securities, such as a put, call or short sale.

No person shall procure from or cause the communication by any insider of unpublished price sensitive information, relating to the Bank or securities listed or proposed to be listed, except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

Federal and state securities laws prohibit the purchase or sale of a company's securities by anyone who is aware of material information about that company that is not generally known or available to the public.

SEC Rule 10b-5 prohibits corporate officers and directors or other insider employees from using confidential corporate information to reap a profit (or avoid a loss) by trading in the Company's stock. This rule also prohibits ?tipping? of confidential corporate information to third parties.

The legislation regarding insider dealing means that anyone who trades on the basis of information that isn't in the public domain is acting illegally.

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Texas Policies and Procedures Designed to Detect and Prevent Insider Trading