MEMBER IDENTIFICATION POLICY

Important Information About Procedures for Opening A New Account
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person or business that opens an account at this Credit Union. When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. We ask for your understanding as we work to support these efforts to maintain the security of your funds and our country. Please speak with a Credit Union staff member if you have any questions or concerns about our identification policies.

HOME MORTGAGE DISCLOSURE ACT NOTICE

The HMDA data about our residential mortgage lending are available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age, and income of applicants and borrowers; and information about loan approvals and denials. HMDA data for many other financial institutions are also available online. For more information, visit the Consumer Financial Protection Bureau’s website (www.consumerfinance.gov/hmda).

For 2017 and prior, to receive a copy of this data send a written request to:

Freedom First Credit Union
Compliance Department
5240 Valleypark Drive
Roanoke, VA 24019

ELECTRONIC FUNDS TRANSFER DISCLOSURE

Our EFT disclosure can be found on page 18 of our Membership Agreement. Please contact us at 540-389-0244 (local) / 866-389-0244 (toll-free) to request a copy of our Membership Agreement.

CONSENT TO RECEIVE ELECTRONIC DOCUMENTATION

This is your consent to receive electronic documentation and contains important information concerning the receipt of documentation electronically. Please be certain to read this consent carefully and notify us at once if any parts are unclear.

The full disclosure can be found on page 17 of our Membership Agreement. Please contact us at 540-389-0244 (local) / 866-389-0244 (toll-free) to request a copy of our Membership Agreement.

FUNDS AVAILABILITY POLICY DISCLOSURE

General Policy. Our general policy is to make funds from your deposits available to you on the same business day we receive your deposit. Electronic direct deposits will be available on the same day of deposit. Once they are available, you can withdraw the funds and we will use the funds to pay checks that you have written. For determining the availability of your deposits, every day is a business day, except Saturdays, Sundays and holidays. If you make a deposit on a business day that we are open, we will consider that day to be the day of your deposit. However, if you make a deposit after closing or on a day that we are not open, we will consider the deposit made on the next business day we are open.

ATM Deposits. Deposits made at automated teller machines (ATMs) that we own or operate will become available on the 2nd business day after the day of deposit. All ATMs that we own or operate are identified as our machines. Deposits made at ATMs that we do not own or operate will become available on the 5th business day after the day of deposit.

Reservation of Right to Hold. In some cases, we will not make all the funds you deposit by check available to you on the same business day we receive your deposit. Funds may not be available until after the 2nd business day following the day of your deposit. However, for checking accounts, the first $225 of your deposit will be available on the 1st business day following the day of your deposit. If we are not going to make all the funds from your deposit available on the same business day, we will notify you at the time you make your deposit. We will also tell you when the funds will be available. If your deposit is not made directly to one of our employees, or if we decide to take this action after you have left the premises, we will mail you the notice by the next business day after we receive your deposit. If you will need the funds from a deposit right away, you should ask us when the funds will be available. Any request for payment against funds on which a hold has been placed will be returned unpaid.

Longer Delays May Apply. We may delay your ability to withdraw funds deposited by check into your account an additional number of days for the following reasons:

  • We believe a check you deposit will not be paid.
  • You deposit checks totaling more than $5,525 on any one day.
  • You deposit a check that has been returned unpaid.
  • You have overdrawn your account repeatedly in the last 6 months.
  • There is an emergency, such as failure of communications or computer equipment.

We will notify you if we delay your ability to withdraw funds for any of these reasons, and we will tell you when the funds will be available. They will generally be available no later than the 7th business day after the day of your deposit. In any case, we reserve the right to refuse an item for deposit or encashment.

Special Rules for New Accounts. If you are a new member, the following special rules will apply during the first 30 calendar days your account is open. Funds from electronic direct deposits to your account will be available on the day we receive the deposit. Funds from deposits of cash, wire transfers, and the first $5,000 of a day’s total deposits of cashier’s, certified, teller’s and federal, state, and local government checks will be available on the next business day after the day of your deposit if the deposit meets certain conditions. For example, the checks must be payable to you. The excess over $5,000 and funds from all other check deposits will not be available until the 9th business day after the day of your deposit. Funds from all other check deposits will be available no later than the 10th business day after the day of your deposit. Further delays may apply.

Holds on Other Funds. If we cash a check for you that is drawn on another institution, we may withhold the availability of a corresponding amount of funds that are already in your account. Those funds will be available to you at the time that the funds from the check we cashed for you would have been available if you had deposited it. If we accept for deposit a check that is drawn on another institution, we may make funds from the deposit available for withdrawal immediately but delay your availability to withdraw a corresponding amount of funds that you have on deposit in another account with us. The funds in the other account would then not be available for withdrawal during the time periods that are described elsewhere in this policy for the type of check that you deposited.

EXCESSIVE OR LUXURY EXPENDITURES POLICY

  1. Purpose
    The purpose of this policy is to establish parameters and internal controls governing the expenditures of Freedom First Federal Credit Union (together with its subsidiaries and controlled affiliates, referred to hereafter as the Credit Union). Expenditures of the Credit Union should be customary, prudent, consistent with applicable laws and regulations, and reasonably related to the Credit Union’s business objectives and needs. This policy identifies expenditures that are excessive or luxury expenditures, creates processes that are reasonably designed to eliminate such expenditures, and establishes accountability for compliance. Routine operating expenses, capital expenditures, and other reasonable expenses are not prohibited by this policy.
  2. Authority
    The Credit Union has authority to provide compensation and benefits that are reasonable. This policy establishes a prohibition on expenditures that are excessive or luxury expenditures as required by the Department of the Treasury’s Emergency Capital Investment Program regulations (31 CFR Part 35), and as may be required by other statutes and regulations.
  3. Responsibility
    This policy is the responsibility of the Credit Union’s board of directors (“Board”). The Board has approved this policy. The Board and internal auditors will review this policy no less than annually.
  4. Scope
    This policy applies to all employees, officers, and directors of the Credit Union with regard to any expenditure of the Credit Union. In making any expenditure on behalf of the Credit Union, employees, officers, and directors should consider whether the expenditure is an excessive or luxury expenditure that is prohibited under this policy.
  5. Excessive or Luxury Expenditures
    “Excessive or luxury expenditures” means excessive expenditures on any of the following to the extent not reasonable or appropriate expenditures for business development, staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the Credit Union’s business operations:
    1. Entertainment or events. This category includes fees, dues, tickets costs related to social, athletic, artistic and dining clubs, activities, celebrations or other events, and similar expenditures. Expenditures for charitable contributions and charitable events are not prohibited under this policy. Entertainment or events expenditures, in an amount less than $1,000 per instance, and $10,000 on an annual aggregate basis per individual, are exempt from this policy.
    2. Office and facility renovations. Office and facility renovations. This category includes costs and allowances for office renovation, including expenditures related to furniture, art, office personalization, interior finishing, design and decoration, and similar expenditures. Office and facility renovations expenditures, in an amount less than $20,000 per instance, and $20,000 on an annual aggregate basis per individual, are exempt from this policy.
    3. Aviation or other transportation services. This category includes charter fees, tickets, slip or docking fees, vehicle installment payments, reservation and travel agent expenses, and similar expenditures associated with transportation services (e.g., airline, train, rental cars, or vans). Mileage reimbursable according to current Internal Revenue Service mileage rates is exempt from this policy. Transportation services, in an amount less than $2,000 per instance, and $15,000 on an annual aggregate basis per individual, are exempt from this policy. The CEO may establish or delegate to an appropriate executive officer the authority to establish processes for reimbursement of reasonable travel expenditures, which processes must be reviewed by executive management no less frequently than annually.
    4. Tax gross-ups. This category includes any reimbursement of taxes owed with respect to any compensation. This category does not apply to tax equalization agreements for employees subject to tax from a non-U.S. jurisdiction.
    5. Other similar items, activities, or events for which the Credit Union may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses. Expenditures related to other items not listed in the preceding categories, in an amount less than $2,000 per instance, and together with all expenditures permitted under this policy, may not exceed $10,000 on an annual aggregate basis per individual, are exempt from this policy . For the avoidance of doubt, reasonable capital investments in technology, equipment, and similar items that expand the long-term capability of the Credit Union to provide products and services to its customers and community are not excessive or luxury expenditures. The CEO may establish or delegate to an appropriate executive officer the authority to establish processes for the evaluation and approval of expenditures in the preceding categories that are not luxury or excessive expenditures and that are not otherwise exempt from this policy. These processes must be reviewed by executive management no less frequently than annually, as well as any additional threshold expenditure amounts per item, activity, or event, or a threshold expenditure amount per employee receiving the item or participating in the activity or event under this policy. Such approvals must be reported to the board of directors (which may be in an appropriate summary form) no less frequently than annually.
  6. Exceptions or Violations
    Any exception or violation of this policy must be promptly reported to the Credit Union’s (i) CEO, (ii) General Counsel, or (iii) officer designated with primary responsibility for overseeing the administration, monitoring, and compliance with this policy. Exceptions and violations must be reported to the Supervisory Committee no less frequently than annually, or more frequently as the nature and severity of violation may warrant. All employees, officers, and directors of the Credit Union must adhere to this policy and will be held accountable for compliance. Any employee or officer who violates this policy may be subject to disciplinary action up to and including termination of employment. Any employee or officer who has actual knowledge of a violation of this policy is required to report such circumstance to their supervisor or the Credit Union’s principal compliance officer or compliance group. The Credit Union prohibits retaliation against any employee or officer for making a good faith report of actual or suspected violations of the Credit Union’s code of conduct, laws, regulations, or other Credit Union policies, including this policy. A finding of retaliation against any such employee or officer may result in disciplinary action up to and including termination. Employees and officers may ask questions, raise concerns, or report instances of noncompliance with this policy and/or any of the existing underlying relevant policies by contacting the EthicsPoint Hotline.
  7. Certification
    On an annual basis, for so long as the Credit Union is a participant in the “ECIP” Treasury program, the Credit Union will deliver to the Department of the Treasury a certification, executed by two senior executive officers (one of which must be either the CEO or CFO) certifying that (i) the Credit Union is in compliance with this policy and (ii) the approval of any expenditure requiring the prior approval of any senior executive officer, any executive officer of a substantially similar level of responsibility, or the board of directors (or a committee of such board), was properly obtained with respect to each such expenditure.

IMPORTANT CREDIT CARD DISCLOSURES

The following disclosure represents important details concerning your credit card. The information about costs of the card is accurate as of 7/27/2023. You can contact us at the number or address below to inquire if any changes occurred since the effective date.

Address: P.O. Box 1999, Salem, VA 24153
Phone: 540-389-0244 (local)866-389-0244 (toll-free)

INTEREST RATES AND INTEREST CHARGES:


Platinum Credit Card Platinum Rewards Credit Card Freedom Private Reserve Credit Card
Annual Percentage Rate (APR) for Purchases
13.74% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
0.00% Introductory APR for 12 months from the date of account opening. After that, your Standard APR will be
15.74% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
0.00% Introductory APR for 12 months from the date of account opening. After that, your Standard APR will be
15.74% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
APR for Cash Advances
16.49% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
18.00% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
18.00% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
APR for Balance Transfers
0.00% Introductory APR for 12 months from the date of account opening.  After that, your Standard APR will be
13.74% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
15.74% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
15.74% to 18.00%
depending on your credit history. This APR will vary with the market based on the Prime Rate.
Penalty APR and When it Applies
18.00%
This APR may be applied to your account if you make a payment that is late 60 days or more.
How Long Will the Penalty APR Apply? If we increase your APRs due to a late payment, we may keep them at this higher level on existing and new balances until you make six consecutive on-time payments.
Paying Interest We will begin charging interest on the transaction date.
Minimum Interest Charge None
For Credit Card Tips from the Consumer Financial Protection Bureau To learn more about factors to consider when applying for or using a credit card, visit the website of the Consumer Financial Protection Bureau at https://www.consumerfinance.gov/learnmore

FEES:


Platinum Credit Card Platinum Rewards Credit Card Freedom Private Reserve Credit Card
Fees to Open or Maintain Your Account

  • Annual Fee:
None
  • Application Fee:
None
Transaction Fees

  • Balance Transfer:
$5.00 for each transfer
  • Cash Advance:
2% of the amount of each cash advance (maximum: $5.00)
  • Foreign Transaction:
1% of each transaction in U.S. dollars if the transaction involves a currency conversion
1% of each transaction in U.S. dollars if the transaction does not involve a currency conversion
Penalty Fees

  • Late Payment:
Up to $15.00 if your payment is late 3 calendar days or more if your unpaid balance is less than $250.01
Up to $25.00 the first time your payment is late 3 calendar days or more if your unpaid balance is greater than $250.00
  • Over-the-Credit Limit:
None
  • Returned Payment:
Up to $25.00 if your payment is returned for any reason

How We Will Calculate Your Balance: We use a method called "average daily balance (including new purchases)."

Loss of Introductory Rate: We may end your introductory Rate and apply the Penalty APR disclosed above if you make a late payment.