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Luxury Expenditure Policy

FIRST WESTERN FINANCIAL, INC. and FIRST WESTERN TRUST BANK
LUXURY EXPENDITURES POLICY

Background and Purpose

The Boards of Directors (collectively, the “Board”) of First Western Financial, Inc. and First Western Trust Bank (collectively, ”First Western”) have adopted this Luxury Expenditures Policy (the “Policy”) to be in compliance with the Emergency Economic Stabilization Act of 2008 (“EESA”), as amended by the American Recovery and Reinvestment Act of 2009 (“ARRA”). Under the Interim Final Rule issued by the United States Department of Treasury on June 15, 2009 (the “Interim Final Rule”), ARRA requires each recipient of funds under the United States Department of Treasury’s Capital Purchase Program (“CPP”) to have in place a company-wide policy regarding excessive or luxury expenditures. The CPP was a special program limited to healthy banks and holding companies that was designed to encourage lending and promote the growth of approved institutions. The purpose of this policy is to fulfill First Western’s obligations under EESA regarding excessive or luxury expenditures.

Pursuant to ARRA and the Interim Final Rule issued thereunder, the Board has adopted this Policy to address expenditures related to (i) dining, entertainment or events; (ii) office and facility furnishing and renovations; (iii) lodging; (iv) aviation or other transportation services; and (v) other similar items, activities or events for which First Western may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses. This Policy applies to all employees of First Western and its subsidiaries.

General Policy

All expenditures covered by this Policy shall be reasonable and appropriate and incurred for staff development, reasonable performance incentives or other similar appropriate purposes conducted in the normal course of business of First Western. In addition, no employee is authorized to approve payment or reimbursement by First Western of any dining, entertainment or event expense, or any expense for lodging or transportation (including by plane) unless the expense is an allowable expense under First Western’s written Expense Reimbursement Policy. Subject to the further restrictions described under “Prohibited Expenditures,” expenditures for office furnishings, remodeling, or redecoration shall be subject to advance written approval of the Chief Executive Officer or Chief Financial Officer in the case of an expenditure described below under “Expenses Requiring Advance Approval.”

Prohibited Expenditures

Renovations: Expenditures for office furnishings, remodeling or redecoration, the aggregate cost of which exceeds $20,000 in the aggregate over a one year period are prohibited. This prohibition does not extend to a general corporate relocation or remodeling impacting a majority of the corporate offices or a newly constructed or acquired profit center, profit center renovation or relocation of profit center.

Private Aircraft: Expenditures for the use of a private aircraft are prohibited, except in emergency situations with the approval of the Chief Executive Officer who must then provide notice to the Chairperson of First Western’s Audit Committee as soon as practicable.

Expenditures Requiring Advance Approval

Prior written approval from the Chief Executive Officer is required for expenditures of $15,000 or more. Prior written approval from the Chief Financial Officer or his or her designee is required for expenditures of $15,000 or less and the expenditures of the Chief Executive Officer. The expenditures requiring approval are expenditures for (i) dining, entertainment, or events; (ii) office and facility furnishings and renovations; (iii) lodging; (iv) aviation or other transportation services; and (v) other similar items, activities or events for which First Western may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses. Notwithstanding the foregoing, prior written approval is not required for the following expenditures: (i) expenditures to comply with building codes and ordinances; (ii) expenditures related to remediation of hazardous conditions or emergency situations; (iii) expenditures to satisfy legal contractual requirements; (iv) expenditures under Board approved annual capital or operating budgets; and (v) expenditures which are allowable expenses under First Western’s written Expense Reimbursement Policy, subject to compliance with the terms and conditions thereof.

Certifications, Approval Procedures and Monitoring

Approval Procedures: The Accounting Department shall establish internal controls to ensure compliance with this Policy and shall prescribe procedures and forms where appropriate in order to make such requests for expenditure.

Certifications and Monitoring: The Chief Executive Officer shall provide a report to the Audit Committee at least annually on the status of this Policy. Within 90 days of the completion of each fiscal year, the Principal Executive Officer and Principal Financial Officer of First Western shall certify that the approval of any expenditure requiring prior approval under this Policy shall have been obtained. This certification shall be provided to the United States Department of Treasury and any other regulatory authorities as may be required.

Reporting of Violations: Anyone who becomes aware of a violation of this Policy (whether intentional or inadvertent) shall report such violation in writing to the Chairperson of First Western’s Audit Committee. Employees are expected to self-report any violations of the employee. The Chairperson will discuss the suspected violation at the next regularly scheduled meeting of the Audit Committee. The Audit Committee will investigate the suspected violation of this Policy in accordance with its procedures established for investigating complaints regarding improprieties in First Western’s internal control or accounting matters. The Audit Committee will report to the Board at its next regularly scheduled meeting on any reported violations and any recommendation with respect to corrective actions. Reports under this Policy and all documents pertaining to the investigation will be retained by First Western for six years. Any violation of this policy shall subject an employee to disciplinary action (including possible termination of employment).

Effective Date

This Policy is hereby effective as of September 3, 2009 and shall remain in effect until the day on which First Western no longer has an outstanding obligation under the CPP to the United States Department of Treasury (not including warrants to purchase the common stock of First Western which may be held by the United States Department of Treasury).