The USA Patriot Act signed by President Bush in October 2001 imposes new anti-money
laundering requirements on brokerage firms and other financial institutions. By
April 24, 2002, all brokerage firms were required to have new, comprehensive anti-money
laundering programs in place.

What is money laundering?
Money laundering is the process
of transferring illegally obtained money so that the funds appear to come from
legitimate sources or activities. Money laundering occurs in connection with a
wide variety of crimes, including fraud, illegal arms sales, racketeering, drug
trafficking, robbery, 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 well taint our financial markets. According to the U.S. State Department,
one recent estimate put the amount of worldwide money laundering activity in excess
of $1 trillion per year.

What are we required to do to combat money laundering?
new rules required by the USA PATRIOT Act, our anti-money laundering program must
designate a special compliance officer, conduct employee training, conduct independent
audits, and establish policies and procedures designed to detect and report suspicious
transactions and ensure compliance with the new laws

As part of these requirements, federal law requires all financial organizations
to obtain, verify and record information that identifies each person who opens
an account. When you request to open an account, we will ask for your name, address,
date of birth, and other information that will allow us to identify you. We will
also ask you to provide a copy of your driver’s license or other identification
documents (such as passport and alien registration card). The information you provide
may be used to perform a credit check and verify your identity using internal sources
and third party vendors. Until you provide the documents or information we need,
we will not be able to open an account or effect any transactions for you.

We thank you for your patience and hope you will support our efforts to deny
terrorist groups access to America’s financial system.

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