CUSTOMER PRIVACY NOTICE - REGULATION S-P

Your privacy is our priority: A guide to how we protect and utilize customer information

Protecting your privacy

At First Analysis, earning and keeping your trust is at the core of our business. We are committed to protecting the personal and financial information you’ve entrusted to us. In accordance with federal privacy regulations, we would like to share with you the principles and policies that we use to ensure the privacy of customer information.

Our pledge to you

While information plays a large role in our ability to provide superior service, we know that our most important asset is our customers’ confidence in us. Keeping customer information secure, and using it only as our customers would want us to, are matters of principle for all of us at First Analysis. With this in mind, here is our pledge to each and every First Analysis customer.

We will:

• Respect the trust you place in us and the confidential nature of the information you provide through your financial relationship with us.
• Limit the collection and use of customer information to what we believe would be useful to service your accounts, administer our business, or tell you about our services.
• Restrict employee access to customer information to those who need to know in order to provide services to you.
• Educate our employees to reinforce the importance of confidentiality and customer privacy.
• Maintain appropriate security standards and procedures to protect information about you.
• Respond quickly to your request to correct inaccurate information.

You can count on us to protect the privacy of the information you have entrusted to us and to provide you with the responsive, professional service you deserve.

Information we collect

The information we collect and maintain about you comes primarily from you during the course of your doing business with First Analysis. This personal information, not available publicly, comes from the following sources:

• Information you provide to us when you fill out account opening documents, complete a form, or make a request for services. This includes your name, address, age, Social Security Number, investment objectives, investment experience, assets and income.
• Information from your transactions with us, such as your account balance, account usage, and margin loan history.
• Information obtained from others, such as credit reporting agencies.

How information helps both you and us

Our mission is clear: to help you reach your financial goals. Information about you and your accounts plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business.

For example, we use information about you to:

• Respond more accurately and efficiently to your requests.
• Identify opportunities to give you more convenience and control by developing new services that may benefit you.
• Secure your accounts and help protect you and First Analysis from fraud.

Keeping information safe

We limit access to the information we have about you to those employees who need to know to provide you with services to help you meet your financial needs.

We maintain appropriate physical, electronic and procedural safeguards to protect your information.

The importance of being accurate

We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process ensures that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, we urge you to notify us immediately.

We limit the sharing of information

To protect your privacy, we limit the information we share outside First Analysis. We conduct our business with great respect for the confidential nature of the information being provided. We will not share information about you except as outlined below.

Sharing information with companies who help us provide you services

We may share the information described under the section captioned “Information We Collect” with companies external to First Analysis to complete a transaction you have requested or to help us service your account. We are highly selective in choosing these companies. All companies with whom we do business are contractually obligated to comply with strict standards regarding security and confidentiality, and the information can be used only for the sole purpose of providing the service we have requested the company to perform.

Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us such as data processing and companies that perform securities execution and clearing services on our behalf.

Sharing information in other situations

We may share the information described under the section captioned “Information We Collect” when we are permitted or required by law. Examples include responding to a subpoena, conducting a fraud investigation or reporting to a credit bureau. We also may share this information when authorized by you.

“Opt-out” of sharing information with affiliated or non-affiliated third parties

First Analysis does not currently share information about you with any affiliate or non-affiliated third party in a manner that would activate an “opt-out” right. If First Analysis desires to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to “opt-out” of such disclosure.

Other applicable laws

First Analysis may also be subject to other privacy requirements under applicable state law. For example, California law places additional limits on sharing information about California residents. With regards to California residents, First Analysis does not currently share information about you with a non-affiliated third party in a manner that would require written consent prior to disclosing the information (an “opt-in”) and we do not currently share information about you with an affiliate in a manner that would require providing you the opportunity to direct that your information not be shared (an “opt-out”). If First Analysis desires to disclose your information in a way that is inconsistent with these policies, we will notify you in advance and provide you with the opportunity to “opt-in” and/or “opt-out” of such disclosure.

An ongoing commitment to your privacy

We are just as committed to protecting the privacy of our former customers as we are our current customers. If you choose to close your account(s) or become an inactive customer, you will continue to be protected by the privacy policies and principles described in this policy.

Thank you

At First Analysis, your business is important to us, and we promise to do our best to safeguard your financial assets and personal and financial information about you. If at any time we can help you further, please do not hesitate to call your registered representative at 1-312-258-1400.

First Analysis
One South Wacker Drive
Suite 3900
Chicago, IL 60606
312-258-1400