Disclosures

Anti-Money Laundering Customer Identification Program disclosure

Providing/Sharing AML Information to Federal Law Enforcement Agencies and Other Financial Institutions

FinCEN Requests Under PATRIOT Act Section 314

Under Treasury's proposed regulations (published in the Federal Register on March 4, 2002), we will respond to a Financial Crimes Enforcement Network (FinCEN) request about accounts or transactions by reporting to FinCEN the identity of the specified individual or organization, the account number, all identifying information provided by the account holder when the account was established, and the date and type of transaction. We will report to FinCEN via the FinCEN website or by any other means that FinCEN specifies. The firm will maintain a log documenting its responses to FinCEN 314(a) requests.

Sharing Information With Other Financial Institutions

We will share information about those suspected of terrorism and money laundering with other financial institutions for the purposes of identifying and reporting activities that may involve terrorist acts or money laundering activities. We will file with FinCEN an initial certification before any sharing occurs and annual certifications afterwards. We will use the certification form found at www.fincen.gov/. We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, including segregating it from the firm's other books and records.

In addition to sharing information with other financial institutions about possible terrorist financing and money laundering, we will also share information about particular suspicious transactions with our clearing broker for purposes of determining whether one of us will file a SAR. In cases in which we file a SAR for a transaction that has been handled both by us and by the clearing broker, we may share with the clearing broker a copy of the filed SAR, unless it would be inappropriate to do so under the circumstances, such as where we filed a SAR concerning the clearing broker or one of its employees.

Information Privacy Policy

ISI Capital, LLC collects non-public personal information about you from the following sources:

• Information we receive from you on applications or other forms; and
• Information about your transactions with us or others

We do not disclose any non-public personal information about you to anyone, except as permitted by law.

If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

ISI Capital, LLC restricts access to your personal and account information to those employees who need to know that information to provide products or services to you.

ISI Capital, LLC maintains physical, electronic, and procedural safeguards to guard your non-public personal information.

SIPC statement

As a member of the Securities Investor Protection Corporation (SIPC) funds are available to meet customer claims up to a maximum of $500,000 in cash and securities, with a $100,000 cash maximum. This protection is provided by the Securities and Investors Protection Act, which is administered by SIPC and is subject to certain conditions and limitations, details of which are available upon request. Further information about SIPC, including the SIPC brochure, may be obtained by contacting SIPC: SIPC Web site address (www.SIPC.org) SIPC telephone number (202-371-8300).

Attribution

Photograph of the Manhattan Bridge courtesy of luminisms.com.