Exhibit
      99.1








**TIB
      Financial Corp. & Subsidiaries**





**Statement
      of Policy with respect to Related Party Transactions**





A.  Introduction.





The
      Board
      of Directors recognizes that related party transactions present a heightened
      risk of conflicts of interest and/or improper valuation (or the perception
      thereof) and therefore has adopted this policy which shall be followed in
      connection with all related party transactions involving the
      Company.





Under
      this policy, any “Related Party Transaction” shall be consummated or shall
      continue only if:







1. the
          Audit Committee shall approve or ratify such transaction in accordance
          with
          the guidelines set forth in the policy and if the transaction is on terms
          comparable to those that could be obtained in arm’s length dealings with an
          unrelated third party,
2. the
          transaction is approved by the disinterested members of the Board of
          Directors, or
3. the
          transaction involves compensation approved by the Company’s Compensation
          Committee

For
        these
        purposes, a “Related Party” is:
  
 an
              executive officer (which shall include at a minimum each executive
              vice
              president and Section 16 officer) or director of the
              Company,
          a
              shareholder owning in excess of five percent of the Company (or its
              controlled
              affiliates),
          a
              party
              who is an immediate family member of an executive officer or director,
              or
          an
              entity which is owned or controlled by someone listed in 1, 2 or 3
              above, or
              an entity in which someone listed in 1, 2 or 3 above has a substantial
              ownership interest or control of such entity.


For
      these
      purposes, a “Related Party Transaction” is a transaction between the Company and
      any Related Party (including any transactions requiring disclosure under Item
      404 of Regulation S-K under the Securities Exchange Act of 1934), other
      than:


transactions
            available to all employees or customers generally,
        transactions
            involving less than $5,000 when aggregated with all similar transactions,
            or
        loans
            made by a banking subsidiary of the Company in the ordinary course of
            business, on substantially the same terms, including interest rates and
            collateral, as those prevailing at the time for comparable loans with
            parties
            not related to the lender, and not involving more than the normal risk
            of
            collectibility or presenting other unfavorable
            features.  B.  Audit
      Committee Approval





The
      Board
      of Directors has determined that the Audit Committee of the Board is best suited
      to review and approve Related Party Transactions. Annually,
      at an Audit Committee meeting, management
      shall recommend Related Party Transactions to be entered into by the Company
      for
      that calendar year, including the proposed aggregate value of such transactions
      if applicable. After review, the Committee shall approve or disapprove such
      transactions and at each subsequently scheduled meeting, management shall update
      the Committee as to any material change to those proposed
      transactions.





In
      the
      event management recommends any further Related Party Transactions subsequent
      to
      the first calendar year meeting, such transactions may be presented to the
      Committee for approval or preliminarily entered into by management subject
      to
      ratification by the Committee; provided that if ratification shall not be
      forthcoming, management shall make all reasonable efforts to cancel or annul
      such transaction.





D.  Corporate
      Opportunity





The
      Board
      recognizes that situations exist where a significant opportunity may be
      presented to management or a member of the Board of Directors that may equally
      be available to the Company, either directly or via referral. Before such
      opportunity may be consummated by a Related Party (other than an otherwise
      unaffiliated 5% shareholder), such opportunity shall be presented to the Board
      of Directors of the Company for consideration.





E.  Disclosure





All
      Related Party Transactions are to be disclosed in the Company’s applicable
      filings as required by the Securities Act of 1933 and the Securities Exchange
      Act of 1934 and related rules. Furthermore, all Related Party Transactions
      shall
      be disclosed to the Audit Committee of the Board and any material Related Party
      Transaction shall be approved
      by the full
      Board of Directors.





F.  Other
      Agreements





Management
      shall assure that all Related Party Transactions are approved in accordance
      with
      any requirements of the Company’s financing ag