FFEC Privacy Policy and 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. All information contained herein can be found on our website at www.ffec.com.

Customer Identification Program
Types of personal information we collect:

When you apply for, open, or maintain an account with us, or when you agree to allow us to provide personalized advisory 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
  • Identification number; for 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
  • Information about you from consumer reporting
  • 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.

Privacy Policy
How We Protect Confidentiality:

We require that commercial entities (custodians, financial institutions, investment firms) with which we share your personal information agree to keep your information confidential. We also prohibit those entities from using or disclosing your information except for a limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted or required by law. Service providers to whom we disclose personal information must agree to contractual requirements consistent with our privacy and security policies. We prohibit our service providers from using personal information except for the specific purpose for which we provide it to them, and we require them to comply with legal obligations applicable to the personal information at issue. FFEC does not sell your personal information to anyone. We receive no compensation for your personal information, nor does your privacy preferences affect the fees for service paid to FFEC. We conduct regular internal audits of our business practices and procedures in order to protect your personal information. FFEC uses procedural, physical, and electronic system safeguards to store and secure information about you in compliance with federal standards. Our systems protect your information from unauthorized access, alteration, and destruction. Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities.

Internet Security
FFEC does not retrieve account or personal information from visitors who browse the public areas of our Web sites. We maintain reasonable physical, electronic, and procedural safeguards to protect your personal information.

Option to Opt Out and Change Notices
FFEC’s Privacy Policy and Customer Identification Program applies to anyone who is a current or former FFEC brokerage client. FFEC provides this information to customers when they open a new account and annually thereafter. If for any reason at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to opt out of such disclosure.

FFEC adheres to the Protocol for Broker Recruiting with certain other brokerage firms and if FFEC remains a signatory to the Protocol as of the effective date of your advisor’s termination from FFEC, then FFEC will permit your financial advisor to take your name, address, phone number, email address and the account title of the accounts serviced (or additional information as permitted if the Protocol is amended) while your financial advisor was associated with FFEC if your advisor joins another Protocol firm.  The retention of this limited information by your advisor under the protocol may occur even if you have exercised your rights limit information sharing. Account representatives will not have access to their client information if they have been terminated for cause or are exiting the investment business. FFEC will observe this procedure until we are advised of changes to the contrary under Regulation S-P.

To limit the personal information that your financial advisor could disclose or take if he or she moved to another brokerage or investment advisory firm and terminated their relationship with FFEC and/or request FFEC to delete your personal information upon account closing, please provide a signed written letter to FFEC that includes the following information:

          • Name
          • Address
          • Phone Number
          • Name of FFEC Advisor

Please note that the privacy choices made by one owner applies to all account owners on the account. To reverse your opt out selection will require a signed written letter to FFEC.

If you have questions or concerns about our Privacy Policy, please contact us at (877) 591-5959 or via email at compliancedept@ffec.com.

Payment Instructions
By regulation, securities trades must be paid for no later than settlement date. All payments should be made payable to the custodian. Please note that we cannot accept cash.

Contact Information
Should you ever have any other questions or concerns regarding your account, please contact us at the following:

First Financial Equity Corporation
Attn: Compliance Department
Terrace Tower
5619 DTC Parkway, Suite 1050
Greenwood Village, CO   80111
(877) 591-5959

Your relationship is very important to us and we thank you for the opportunity to serve your financial needs. We look forward to a long relationship with you.

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