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Privacy Policy
Statement
In opening and servicing its customers'
accounts CCII will collect the following personal information:
- Identifying information, e.g. customers' name,
address, telephone number, social security number, or other official
identifying information.
- Application information, e.g. information about
customers' assets, income, investment goals and risk preferences; and
- Transactions information, e.g. account activity
information
CCII will use its customers' personal
information in ways that comply with the purposes for which the information was
obtained. CCII, for example, will use customers' information to process the
customers' requests and transactions, to provide customers additional
information about products and services, and to evaluate customers' financial
needs and suitability for particular products and services.
CCII will share customers' personal
information with its agents or affiliates, and with its clearing firm. CCII
will limit the collection and use of personal information to what is necessary
to administer its business and to deliver professional services to its
customers. Such services may include advising the customer about the firm's
products and services, the products and services of CCII's affiliates, and
other opportunities that may be of interest to customers.
CCII will not share personal
information with others except as stated in this policy, and unless it gives
its customers additional notice or obtains their permission to do so. However,
CCII reserves the right to disclose or report customers' personal
information:
- To CCII's clearing firm, as CCII deems necessary
or appropriate to handle, process and clear transactions in accounts.
- Where CCII believes in good faith that disclosure
is required under law to cooperate with regulatory agencies and law enforcement
authorities.
- To perform necessary credit checks or collect or
report debts owed to CCII.
- To protect CCII's rights or property; or
- Upon reasonable request by a mutual fund or
relating to other investments in customers' account.
CCII does not sell its customers' or
prospective customers' personal information. CCII will protect the
confidentiality of its customers' personal information. CCII's corporate
policies require that employees, with access to confidential information on
customers and prospects, may not use or disclose such information except for
business purposes. All employees are required to safeguard such
information.
CCII will continue to improve its
efforts to protect customers' personal information and to make every effort to
keep such information accurate and current. In the event that a customer
identifies any errors in his or her personal information or wishes to change
such information, the customer should promptly request CCII to correct and
update its records.
Business
Continuity Statement
As a result of our ever-changing and
evolving world, it has become necessary for firms in the financial services
industry to take steps to ensure that they are prepared to meet customer needs
and resume business operations in a timely manner in the event of a significant
business disruption (SBD).
There are several types of SBDs varying
in severity and scope that may occur on an internal or external level. An
internal SBD, such as fire in CCII's building, would only affect the firm's
ability to conduct its normal business. An external SBD, such as a hurricane,
regional power outage, or terrorist attack would affect the operations of
several firms or the financial markets as a whole.
All members of the NASD are required to
have a Business Continuity Plan (BCP) in place, to update their BCP upon any
material change, and at a minimum to conduct an annual review of their BCP.
Each member also must disclose to its customers how its BCP addresses the
possibility of a future SBD and how the member plans to respond to events of
varying severity and scope.
CCII's policy is to respond to any SBD
in a manner that prioritizes the immediate safety of its employees,
preservation of the firm's property, and a quick recovery in order to meet and
continue the business of its customers. If the SBD is determined to be
catastrophic to the level that CCII is unable to continue operating, management
would ensure that customers have prompt access to their funds and
securities.
To ensure that the firm continues to
function as a broker/dealer and to service its clients following a significant
business disruptive event the following steps have been implemented:
- Alternate office location: In the event that the
main office becomes inoperable, CCII will shift its operations to its
designated back-up facility which is reasonably distant from the main office so
as to reduce the chance that it will be affected by the same SBD.
- Back-up books and records: CCII maintains
back-ups of all customers' files and other internal books and records at an
off-site facility.
- Third party business relationships: CCII has
business relationships with several entities upon which it relies for various
services. Such entities include CCII's clearing firm, banks, telecommunications
providers, etc. CCII has contacted its essential third parties to assess the
impact that varying types of SBDs might have on the services they provide.
Based on that information CCII has been able to develop alternate plans to
counter any interruptions in these services experienced during a SBD.
- CCII has back-up arrangements to enable its staff
to maintain reasonable communication with customers, clearing firm, vendors and
regulators.
Please be advised that business
continuity plans are subject to change and modification. CCII intends to update
and test its business continuity plans as business conditions and technology
change. Should you have any questions concerning the business continuity plan,
please submit a written request to CCII.
Investor
Protection
Every customer of Capital and Credit
International, Inc. is covered by the Securities Investor Protection
Corporation (SIPC).* In addition, Pershing provides account protection for the
net equity of your securities positions and cash in your account. Of that
total, SIPC provides $500,000 of net equity protection, including $100,000 for
claims for cash awaiting reinvestment.
- The SIPC will only protect a customer's
securities and funds if the brokerage firm fails, and does not protect against
a decline in the market value of customers' funds or securities. Additionally,
investors should be aware that investments are subject to market risk;
accordingly, neither CCII nor Pershing, LLC can protect against losses that may
occur from market volatility and/or changes in the market value of
investments.
Anti-Money
Laundering Disclosure
The USA PATRIOT Act was designed to
assist in detecting, deterring and punishing terrorists in the United States
and abroad. The Act imposes anti-money laundering requirements on brokerage
firms and other financial institutions. CCII, as required, has implemented a
comprehensive anti-money laundering program. To help its customers, CCII
provides the following information about money laundering and the measures it
takes in implementing the USA PATRIOT ACT.
- What is money laundering? Money
laundering is the process of disguising illegally obtained money so that such
money appears to come from legitimate sources or activities. Money laundering
occurs in connection with a wide variety of crimes, including illegal arms
sales, drug trafficking, robbery, fraud, racketeering, and terrorism.
- How big is the problem and why is it
important? The use of the U.S. financial system by criminals to
facilitate terrorism or other crimes could taint the U.S. financial markets.
According to the U.S. State Department, a recent estimate puts the amount of
worldwide money laundering activity at about $1 trillion yearly.
- What is CCII required to do to eliminate
money laundering? Under USA PATRIOT Act, CCII is required to designate
an anti-money laundering compliance officer, establish training programs for
appropriate personnel, arrange for independent testing for compliance with the
related laws and regulations, and establish policies and procedures to detect
and report suspicious transactions. As part of its anti-money laundering
program, CCII will ask its customers to provide various identification
documents. Until such documents and information are provided and identify is
verified, CCII may not be able to open an account or effect any transaction for
any prospective customers.
The management of CCII thanks its
customers and prospective customers for their support in the effort to deny
access of terrorist groups, money launderers and other criminals to the U.S.
financial system.
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