FFEC Customer Identification Program

First Financial Equity Corporation (FFEC) is committed to protecting our customers’ personal information. At FFEC, we take the responsibility to safeguard the confidentiality of clients’ information we are required to obtain very seriously. This Policy answers some questions about what personal information we collect and why, what we do with it, and how we protect it. We do not disclose personal information about our customers to non-affiliated third parties, except as described below.

Customer Identification Program
Types of personal information we collect:

When you apply for, open, ormaintain an account with us, or when you agree to allow us toprovide personalized financial services, or apply for a financial product or service, we collect the following types of information:

        • Information you provide on applications or other forms, or through discussions, we have with you or your representatives, such as your name, address, date of birth, income, employment information, investment experience, risk tolerance, and information about your personal investment goals or objectives.
        • Information about your transactions with or through us, such as your account balance, trading activity, loan amount, and account history, if applicable.
        • A photocopy of your driver’s license or other identifying documents.
        • Identification number; for U.S. citizen (Social Security number or employer identification number) Non-U.S. citizen: passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you.
        • Information you provide us about your external financial accounts for us to provide you special product and service features.
        • Information about you from consumer reporting agencies.
        • A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government issued business license, a partnership agreement or a trust agreement.

Why We Collect Information
Federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account. In addition, we collect and maintain information about you to evaluate your financial needs in order to provide you with our financial products and services. The information gathered from you is vital to determine the suitability of investment recommendations. FFEC employees are instructed to use strict standards of care in handling the personal, confidential information for our clients. In general, we collect, use and disclose personal information to meet the needs of our customers and our business purposes, including:

        • To provide the products and services you request.
        • The day-to-day operation and maintenance of accounts and financial services.
        • To design and improve our financial services and related products and services.
        • To comply with our regulatory, legal and ethical obligations, including warrants, subpoenas, and court orders, or with a regulatory, government authority or law enforcement agency request, and in connection with criminal investigations or to meet tax reporting requirements.
        • To contact you (including by way of email) in response to your inquiries to safeguard your interests.
        • To investigate suspicious activities.
        • To defend against unlawful intrusion into your account and protect our rights and property.

What happens if I do not provide the information requested or my identity cannot be verified?
FFEC will not open an account or carry out transactions for you

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