Pursuant to the Gramm-Leach-Bliley Act*, all companies dealing with the Consumers’ Non-Public Personal
Information (NPI) are required to ensure the protection and safeguarding of such information both written and
electronic. NPI is defined as personal in nature and not subject to public availability. NPI includes Social Security
numbers, credit and income histories, credit and bank card account numbers, phone numbers, addresses, names,
and any other personal customer information received by a financial institution that is not public.
*Gramm-Leach-Bliley Act: 15 U.S. Code § 6801. Protection of nonpublic personal information
(a) PRIVACY OBLIGATION POLICY
It is the policy of Congress that each financial institution has an affirmative and continuing obligation to
respect the privacy of its customers and protect the security and confidentiality of those customers’ nonpublic
(b) FINANCIAL INSTITUTIONS SAFEGUARDS. In furtherance of the policy in subsection (a), each agency or authority
described in section 6805(a) of this title, other than the Bureau of Consumer Financial Protection, shall establish
appropriate standards for the financial institutions subject to their jurisdiction relating to administrative, technical,
and physical safeguards
(1) to ensure the security and confidentiality of customer records and information;
(2) to protect against any anticipated threats or hazards to the security or integrity of such records; and
(3) to protect against unauthorized access to or use of such records or information which could result in
substantial harm or inconvenience to any customer.
To ensure compliance with this policy, the broker must certify that all steps are taken to prevent consumers’
personal information from being accessed at any time within the broker’s offices or through email communication.
The undersigned has read and understood the responsibilities under Non-Public Personal Information and
Safeguard Security Policies: