First Internet Bancorp
Investor Relations and Communications Policy

Policy
First Internet Bancorp (the “Bancorp”) has adopted this policy (the “Policy”) regarding investor relations and communications in order to provide information to its shareholders on an efficient basis and in compliance with applicable laws and regulations. This Policy will be reviewed by the Bancorp on a regular basis and updated as necessary to ensure its effective operations.

The Bancorp will appoint an investor relations representative who will be responsible for all investor correspondence and communications. Bancorp employees and management must channel investor questions and correspondence through the investor relations representative for response and resolution.

Available Information
The Bancorp's common stock currently trades on the Over-The-Counter Bulletin Board (OTCBB) under the symbol FIBP. The Bancorp's common stock is not currently registered under the Securities Exchange Act of 1934 and, accordingly, the Bancorp does not file periodic reports, proxy statements and other materials with the Securities and Exchange Commission. However, as explained below, the Bancorp publicly discloses on its website quarterly financial information in the form of earnings releases and financial statements and informational letters from management, as well as information relating to its annual meetings of shareholders. In addition, the Bancorp's banking subsidiary, First Internet Bank of Indiana, files quarterly financial information with the FDIC which can be accessed at https://cdr.ffiec.gov/public/.

Investor Communications
The investor relations representative will ensure that communications with investors are made in accordance with the guidelines for standard communications, which are as follows:

	The Bancorp routinely posts important information for investors on its website, http://www.firstinternetbancorp.com. The Bancorp also uses its website as a means of complying with its disclosure obligations under Regulation FD. Accordingly, investors should monitor the Bancorp's website. The website page will contain links to recent financial statements, press releases, letters to shareholders, presentations by management and similar communications, as well as a link to a “frequently asked questions” section. Alternative methods for contacting the investor relations representative are also published on the website page.
	The Bancorp maintains an e-mail box entitled investors@firstib.com. Investors and other interested persons may submit correspondence to this e-mail address. The investor relations representative will determine what, if any, response will be made. E-mails may be responded to directly (if inquiries are deemed private in nature such as an inquiry pertaining to a lost stock certificate) or through the “frequently asked questions” section (if inquiries are not deemed private in nature). If a question has been answered in the “frequently asked questions” section, the inquiring investor may be notified of that fact in a reply e-mail.
	To minimize the potential for inadvertently disclosing material non-public information on a selective basis, as a general rule, the Bancorp will not disclose material non-public information in meetings, telephone calls, or other "one-on-one" communications with individual investors and market professionals, including broker-dealers, investment advisors, and investment funds.
	As a general rule, the Bancorp will not discuss its financial or business performance or prospects during the period that begins two weeks prior to the end of quarter through the time that the Bancorp publicly releases results for that quarter.
	The Bancorp will provide advance notice of shareholder meetings through its website page. In addition, the Bancorp will mail a notice of meeting to each shareholder of record, using the most current address on file. The Bancorp will issue only one notice per shareholder. The Bancorp will mail such notice to allow sufficient time for the shareholder to receive, review, and respond to the notice.
	In some circumstances, it may be desirable for the Bancorp to provide information regarding its expected financial or business performance (such as regarding its expectations for revenues and net income for a quarter) before it is prepared to issue its quarterly earnings release. For example, such a release might be appropriate when there is a concern that materially positive or negative news may have leaked, or for other reasons. The determination whether to pre-release information about a quarter and what information to include in such a release will be made by the management of the Bancorp, including the investor relations representative.

Forward-Looking Statements
The Bancorp may from time to time include in its communications matters that are "forward-looking statements" within the safe harbor provisions of the Private Securities Litigation Reform Act of 1995. The forward-looking statements will be based on current expectations, estimates, forecasts and projections of Bancorp financial information as well as the beliefs of and assumptions made by management. Such statements can be identified by the use of terms such as “may”, “will”, “should”, “believe”, “expect”, “anticipate”, “estimate”, “continue” or comparable terminology. These statements are not guarantees of future performance and involve risks, uncertainties and assumptions that could cause actual outcomes and results to differ materially from the forward-looking statements. These risks and uncertainties include, but are not limited to, declines in asset quality, adverse effects of changes in the interest rate environment, increases in competition, risks of litigation, adverse effects of changes in accounting policies and procedures and laws and regulations, including financial reform legislation, and other factors which accompany the forward-looking statements. Any forward-looking statements will be based on information available as of the date they were made and the Bancorp will not undertake to update any forward-looking statements made by the Bancorp or on its behalf.