Anti Money Laundering Program

Under the U.S. Patriot Act, we are required to establish and maintain an Anti-Money Laundering Program (“AML”). 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 who opens an account. When you open account, we will ask for your name, address, date of birth and copy of a valid form of government-issued photo identification.

Business Continuity Plan Summary

We have prepared, and always maintain a current Business Continuity Plan (“BCP”) in compliance with NASD Rule 3510. This document summarizes our plan to continue business and meet our existing obligations to customers in the event of a Significant Business Disruption (“SBD”).

Our firm’s policy is to respond to a SBD by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. We will make every reasonable effort to meet our obligations to customers at all times. Our plan anticipates two kinds of SBD’s; internal and external. Internal SBD’s affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBD’s prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm. In the event that we determine we are unable to continue the normal conduct of our business, due to any of the scenarios described above or any other circumstances, we will enact our BCP in order to assure customers prompt access to their funds and securities. Our BCP outlines the back-up facilities and arrangements that will be utilized in these circumstances. We will make every reasonable effort to continue the conduct of business during any SBD, employing the use of our BCP. We plan to continue the conduct of business during any SBD unless circumstances prohibit us from doing so. If, for any reason, at any time, we are forced by circumstances outside our direct control to discontinue business, we will immediately determine our planned recovery time and communicate those plans to all concerned parties. Our BCP is subject to modification, update, and improvement at any time so that we may constantly assure ourselves, our customers, and any other concerned party of our readiness to confront a SBD.

Information Privacy Policy

EFX collects non-public information about you from the following sources:

• Information we receive from you on account applications or other forms
  
• Information about your transactions with us or others
  
• Information we receive from a consumer reporting agency

We do not disclose any non-public information about you to anyone, except as permitted by law. We maintain physical, electronic and procedural safeguards in compliance with federal standards to protect your information. If you decide to close your account (s) or you become an inactive customer, we will adhere to the privacy policies and practices as described in this notice