Patriot Act, Money Laundering, How Big, Eliminate, Privacy Commitment, We Collect, Disclose, Confidentiality, Questions

Anti-Money Laundering Requirement

The USA PATRIOT Act: The USA PATRIOT Act, signed by President Bush in 2001, is designed to detect, deter, and punish terrorists in the United States and abroad. The Act imposes new anti-money laundering requirements on brokerage firms and financial institutions. By April 24, 2002, all brokerage firms were required to have new, comprehensive anti-money laundering programs.

To help you understand these efforts, we want to provide you with some information about money laundering and our steps to implement the USA PATRIOT Act.

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What is money laundering? Money laundering is the process of disguising 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 illegal arms sales, drug trafficking, robbery, fraud, racketeering, and terrorism.

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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 puts the amount of worldwide money laundering activity at $1 trillion a year.

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

As part of our required program, we may ask you to provide various identification documents or other information. Until you provide the information or documents we need, we may not be able to open an account or effect any transactions for you.

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

Our Privacy Commitment to You. When you work with a financial services professional to develop a financial plan or purchase an insurance or investment product, you may share highly personal information about your health, assets, income, estate, business and family. The information we collect is critical to providing superior products and service. But we recognize that protecting the privacy and security of this information is an important responsibility.

The following information will help you understand our privacy policy and how we will handle and maintain confidential customer information to fulfill our obligation to protect your privacy. You are receiving this notice because you are a Girard Securities, Inc. customer, or considering becoming our customer. This notice describes Girard's practices and policies for handling your personal financial information.

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What Information Do We Collect? We collect personal information to help us serve your financial needs, offer new products and services, provide customer service and fulfill legal and regulatory requirements. "Personal Information" refers to nonpublic personal financial and health information we obtain from you in connection with providing you with a financial product or service. We may obtain this information directly from you or from other sources.

The type of information that we collect varies, based on the products or services involved. It may include:

• Information we receive from you on applications and related forms, such as name, address, social security number, assets and income;
• Information about your transactions and relationships with us and our affiliates, such as products or services purchased, account balances and payment history;
• Information we receive from consumer reporting agencies, such as credit relationships and history, and;
• Information we receive from third parties in order to issue and service your policies, such as motor vehicle reports and medical information.

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What Information Do We Disclose? Girard Securities, Inc. may disclose your non-public personal information as part of servicing and maintaining your policy, contract or account, and for other legally required and permitted purposes.

In the normal course of business, we may share personal information with persons or entities involved in servicing and administering products and services on our behalf. These could include: your agent or broker, insurance companies, consumer reporting agencies, medical consultants, firms assisting in administration of policies and claims, companies that perform marketing services on our behalf or other financial institutions with whom we have joint marketing agreements, and other service providers and affiliates assisting us.

We will not disclose personal information about current or former customers to non-affiliated third parties, except as permitted or required by law. We do not sell any personal information about you to any third party.

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How Do We Protect the Confidentiality of Your Information? Girard Securities, Inc. has procedures in place that limit access to personal information to employees, representatives and service providers who need to know the information to perform business services or market products on our behalf. We also educate our employees about the importance of protecting the privacy and security of confidential personal information. Finally, we maintain physical, electronic and procedural safeguards that comply with federal and state regulations to guard your personal information.

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Please Contact Us With Any Questions. Confidentiality is an established hallmark of Girard Securities, Inc.'s business. We understand the need to safeguard the personal information that you disclose to us, and we have an established tradition of discretion and respect for our customers' privacy. We reinforce this daily in the way we routinely handle sensitive client information as part of our normal business operations. We will update our policies and procedures when necessary to ensure that your privacy is maintained and that we conduct our business in a way that fulfills our commitment to you. If we make any material changes in our privacy policy, we will provide our customers with an updated notice. If you have any questions about Girard Securities, Inc.'s privacy policy, please contact us at 858-622-2140.

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