SECURITY BREACH INCIDENT RESPONSE AND CONSUMER NOTIFICATION PLAN TABLE OF CONTENTS PROGRAM OVERVIEW... DEFINITIONS... REPORTING A SECURITY BREACH...

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1 SECURITY BREACH INCIDENT RESPONSE AND CONSUMER NOTIFICATION PLAN TABLE OF CONTENTS PROGRAM OVERVIEW... DEFINITIONS... REPORTING A SECURITY BREACH... CONTAINMENT AND CONTROL... INVESTIGATING A SECURITY BREACH... LAW ENFORCEMENT COORDINATION... NOTIFICATION ASSESSMENT... INTERNAL COMMUNICATION PROTOCOL... REGULATOR NOTIFICATIONS... LEGAL NOTIFICATIONS... THIRD PARTY NOTIFICATIONS... CONSUMER CREDIT REPORTING AGENCY NOTIFICATION... NOTIFICATION CONTENT... NOTIFICATION COORDINATOR... CONSUMER ASSISTANCE... RECORDKEEPING AND REPORTING... APPENDIX A EXAMPLES OF REPORTABLE SECURITY BREACH INCIDENTS... APPENDIX B - CONSUMER NOTIFICATION LETTER TEMPLATE... APPENDIX C IDENTITY THEFT CONSUMER EDUCATION BROCHURE... APPENDIX D CONSUMER NOTIFICATION ENVELOPE... APPENDIX E CONSUMER ASSISTANCE FAQS... APPENDIX F CONSUMER NOTIFICATION KEY CONTACT LIST...

2 ««Date»» ««Name»» ««Address»» ««City, State, Zip»» Dear ««Mr./Ms. Last Name»», We recently became aware that [description of incident that lead to unauthorized access or use of consumer s sensitive information, the type of information that was accessed or used and the steps ABC Financial taken to prevent further unauthorized access or use. ] While we do not have any evidence to indicate that your information was used in any inappropriate manner, it is very important that you carefully read the enclosed brochure and take the precautionary measures we recommend. The brochure will guide you through the steps you need to take to: contact the major credit bureaus and place a fraud alert on your credit reports; review your recent account activity for unauthorized charges or accounts; monitor all of your accounts over the next twelve to twenty-four months; and take action should any unauthorized activity appear on your credit report. To assist you in this effort, ABC Financial would like to purchase on your behalf a free, one-year subscription to [name of credit monitoring service]. This is a daily credit monitoring program that can help you detect early signs of identity theft. Offered in partnership with [name of credit bureau], a leading national credit reporting company, [name of credit monitoring service] monitors your credit report daily and sends you notifications of critical information changes. For security reasons, to obtain [name of credit monitoring service] credit monitoring and notification, you will need to log on to [website url ] and complete the secure online form. You will need to enter the authorization code indicated below on page two of the online form to complete the complimentary enrollment. Authorization Code: << << Unique 9 character code >> >> We deeply regret this incident. [As applicable: We are working closely with law enforcement and continuing our investigation into this matter.] If you have questions about this incident, please call our special services hotline at [1-866-XXX-XXXX] between the hours of 7:00 AM and 7:00 PM Central Time, Monday through Friday, and a specially trained representative will be ready to assist you. Sincerely, [Signature] [Typed Name] Office of the President Enclosure

3 What is Countrywide doing to help protect you? Protecting the confidentiality and security of our customers personal information is a priority for Countrywide. We ve taken very specific steps to reduce the chance that identity thieves can harm our customers credit. INDUSTRY ASSOCIATIONS Countrywide works in concert with industry groups in developing legislation, policies and practices to fight identity theft and other crimes in the businesses we operate in. TRAINING We train employees in customer identification and authentication to reduce the chance of an account or loan being opened in your name without your permission. FRAUD HOTLINE Countrywide provides a fraud hotline for reporting crimes, including identity theft, involving Countrywide. If you think your identity has been stolen, and suspect it may affect any of your loans or accounts with Countrywide, please call our toll-free, 24/7 Fraud Hotline immediately at: CUFRAUD ( ). CREDITGUARD Offered through Countrywide s LandSafe subsidiary, CreditGuard provides round-the-clock monitoring of your credit report and notification if any critical information changes. For more information, visit: Additional information can be found under our Privacy & Security section at: Equal Housing Lender Countrywide Financial Corporation. Trade/service marks are the property of Countrywide Financial Corporation and/or it s subsidiaries /05 What you should know about today s fastest growing crime: IDENTITY THEFT

4 At Countrywide, we are fully committed to fighting identity theft and arming you with all the facts that can help you avoid becoming a victim. WHAT IS IDENTITY THEFT? Identity theft is when someone takes and uses your personal information (such as your name, Social Security or credit card number) in order to steal money from your accounts, establish fraudulent accounts in your name, or borrow against your credit. HOW DOES IT HAPPEN? They steal mail (such as account statements, new checks and credit offers) from mailboxes, trash, or even out of your home or office. They take credit card and personal identification from your purse or wallet. They trick you into divulging personal information through phony websites or scam s, often posing as your bank or credit card company. HOW CAN I AVOID BECOMING A VICTIM? Completely destroy or shred all papers with personal information before throwing them out. Be careful who you give your information to over the phone. NEVER give out your Personal Identification Number (PIN) or passwords. Report lost or stolen credit cards, checks or identification immediately. Shop online only with reputable merchants in secured areas. Never write your Social Security Number or driver s license number on your checks. Never leave your mail in an unsecure mailbox. WHAT SHOULD I DO IF I BECOME A VICTIM? STEP 1: Contact the three major credit bureaus listed below. Ask them to send you a copy of your credit report and instruct them to place a fraud alert on your record. Equifax P.O. Box Atlanta, GA Experian P.O. Box 2002 Allen, TX TransUnion P.O. Box 1000 Chester, PA STEP 2: Close accounts that have been tampered with or opened fraudulently. Ask the issuer to promptly clear your credit record. STEP 3: Call your local police or sheriff s department and file a complaint with the Federal Trade Commission at: or IDTHEFT ( ).

5

6 Consumer Notifications - Consumer Assistance FAQs BACKGROUND (varies by notification): [Description of incident that lead to unauthorized access or use of consumer s sensitive information, the type of information that was accessed or used and the steps taken to prevent further unauthorized access or use.] Be Prepared to Answer the Following Frequently Asked Questions Question 1. What information about me was, or may have been, compromised? Question 2. I believe my identity may have been stolen, what should I do? Question 3. Is law enforcement involved in the investigation? Question 4. How soon after you learned about the incident did you notify me? Question 5. The brochure enclosed with the letter said I should close accounts that have been tampered with. Did the information about me that was compromised include my credit card number(s)? Question 6. What if I find out that my identity is stolen as a result of this incident, will your company reimburse me for my losses? What assistance you re your company provide if my identity is stolen? Question 7. I m already a victim of identity theft. What is your company going to do to reimburse me for my losses? Question 8. When will I know if my identity has been stolen? How will I know? Question 9. What is credit monitoring? Question 10. What good will credit monitoring do? Question 11. What is involved to enroll in credit monitoring? Question 12. How long will it take until I begin receiving credit monitoring notices? Question 13. Do I need to enroll in the credit monitoring service if I have contacted the credit bureaus and placed a fraud alert on my file? Question 14. If I enroll in credit monitoring, do I still need to contact the credit bureaus to place a fraud alert on my file? Question 15. If I place a fraud alert on my file, will this affect my credit? If so, how?

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