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EDI Financial PRIVACY NOTICE
EDI Financial (“EDIF”) relies
on access to your personal financial information so that we
can make appropriate recommendations to you regarding the products
and services offered through us.
EDIF is committed to safeguarding your personal information
provided to us by you. This notice, required under SEC Regulation
S-P, describes our privacy policy and how we handle and protect
your personal information. The provisions of this notice apply
to all present and former EDIF customers.
We collect personal information about you so that we can make
recommendations about products and services we offer that may
be of interest to you. We collect nonpublic personal information
from the following sources:
- information you provide to EDIF
on applications and other forms (such as your name, address,
occupation, assets, and income);
- information about your transactions with EDIF, our
affiliates, or others, and/or;
- information we receive from
consumer reporting agencies (such as your credit history
and creditworthiness) and other entities not affiliated with
EDIF.
We restrict access to your personal information to those employees
who need to know that information in order to provide products
and services to you. Our employees are required to maintain
and protect the confidentiality of your personal information
and must follow established procedures to do so. To comply
with applicable laws and regulations, we maintain physical,
electronic, and procedural safeguards that comply with applicable
laws and regulations to protect your personal information.
We may share your personal information described above with
our affiliates for business purposes, such as marketing new
products and services, servicing your account, and as permitted
by law. Our affiliates are companies controlled or under common
control of our holding company. The information we share with
affiliates may include the information described above (such
as name, address, income and information related to your account
with EDIF.
We may share the personal information described above for
business purposes relating to your personal investments and/or
accounts with the following companies not affiliated with us:
- financial service institutions,
such as mutual fund companies, securities brokers, insurance
agencies, clearing brokers, and banks, with whom we have
joint marketing agreements (such as agreements to market
financial services or products that they jointly offer, endorse
or sponsor with us); or
- companies under contract to perform
services for us or on our behalf (such as vendors providing
data processing, computer software maintenance and development,
transaction processing and marketing services).
We may also disclose personal information with non-affiliated
companies and regulatory authorities as permitted by applicable
law. For example, we may disclose personal information to cooperate
with regulatory authorities and law enforcement agencies and
as necessary to protect our rights or property. Except as described
in this privacy policy, we will not use your personal information
for any other purpose unless we describe how such information
will be used at the time you disclose it to us or we obtain
your permission to do so.
Questions you may have regarding this notice
Please direct any questions you have to EDI Financial, Inc.,
Attn: Michael Young, 12221 Merit Drive, Suite 1020, Dallas,
TX 75251. Telephone# (214) 528-4090.
CUSTOMER IDENTIFICATION PROGRAM NOTICE
To help the government fight the funding of terrorism and money
laundering activities, federal law requires financial institutions
to obtain, verify, and record
information that identifies each person who opens an account.
This Notice answers some questions about your firm’s
Customer Identification Program.
What types of information will I need to provide?
When you open an account, your firm is required to collect
information such as the following from you:
- Your name
- Date of birth
- Address
- Identification number:
- U.S. Citizen: taxpayer identification
number (social security number or employer identification
number)
- Non-U.S. Citizen: taxpayer identification number,
passport number, and country of issuance, alien identification
card number, or government-issued identification showing
nationality, residence, and a photograph of you.
You may also need to show your driver’s
license or other identifying documents.
A corporation, partnership, trust or other legal entity may
need to provide other information, such as its principal place
of business, local office, employer identification number,
certified articles of incorporation, government-issued business
license, a partnership agreement, or a trust agreement.
U.S. Department of the Treasury, Securities and Exchange Commission,
NASD, and New York Stock Exchange rules already require you
to provide most of this information. These rules also may require
you to provide additional information, such as your net worth,
annual income, occupation, employment information, investment
experience and objectives, and risk tolerance.
What happens if I don’t provide the information requested
or my identity can’t be verified?
Your firm may not be able to open an account or carry out transactions
for you. If your firm has already opened an account for you,
they may have to close it.
We thank you for your patience and hope that you will support
the financial industry’s efforts to deny terrorists and
money launderers access to America’s
financial system.
BUSINESS CONTINUITY PLAN
We have developed a business continuity plan that covers the
broker-dealer operations of EDI Financial, Inc. (“EDIF”).
It is designed to ensure that EDIF is prepared to continue
providing service to our clients in the event that we experience
a significant disruption of any kind to our business operations.
The plan addresses business disruptions of varying severity
and scope at our headquarters. It provides for testing at
least annually and in response to any material changes affecting
our business, and takes into consideration our critical third-party
relationships. Although it is impossible to anticipate every
scenario, we believe that our plan will enable us to resume
doing business upon the occurrence of those events that are
most likely to affect our headquarters and our data centers.
As part of our plan, we have a geographically diverse back-up
facility complete with space for key employees as well as telephones,
computers, and other necessary hardware. This facility is located
on a separate power grid from our headquarters and is serviced
by a different power provider. It has local and long distance
telephone service providers that are distinct from those that
service EDIF’s headquarters.
What follows is a description of how EDIF will respond to
the following four types of disruptions: (1) a firm-only disruption,
(2) a disruption that affects a single building, (3) a disruption
that affects the entire city or business district, and (4)
a disruption that affects the entire Southwest region. We have
also included information about how long we expect it to take
us to recover from these disruptions.
To respond to a disruption that affects only EDIF, such as
a computer virus, we have developed an emergency response/crisis
management team. This team has, in the past, successfully guided
us through disruptions that have affected our operations and
has done so through the use of a crisis communications system
and through procedures that address life, health, and safety
issues; damage assessment; damage mitigation; personnel mobilization;
and mission-critical systems. If this type of disruption takes
place, we intend to restore all critical services within one
day after the disruption occurs. However, in light of the various
types of disruptions of this nature that could take place,
it may take longer for us to resume operations in one or more
of the services during any particular disruption.
In the event of a disruption that affects EDIF headquarters
and such as a fire in the building, our plan calls for a response
involving multiple locations. We will resume critical services
by moving key personnel to various locations and, to the extent
necessary to our back-up facility. Certain key personnel may
also work remotely by connecting to the network from a remote
location. In addition to relocating key personnel to back-up
faculties, we will, if necessary, transfer responsibility for
certain operations and support services to our offsite offices.
We intend to resume operations in all of our critical service
areas within one day after a disruption of this nature occurs.
It may, however, take as long as two or three days to continue
doing business in one or more critical service areas depending
on the availability of data a applications from our data centers.
If a disruption significant enough to affect
the entire city of business district, such as a terrorist attack,
cuts off access to EDIF headquarters, under our plan we will
resume critical services at our back-up facilities and certain
EDIF offsite offices. As above, certain key employees will
work remotely and certain operations and support services would
be handled by other EDIF offices. We intend to resume operations
in all of our critical service areas within one day after a
disruption on the availability of data and applications from
our data center and on the availability of key employees.
In the event of a disruption that affects the
entire Southwest region such as a regional power outage, we
will resume critical service areas from back-up facilities
and certain of EDIF offsite locations. Although EDIF intends
to resume operations within one day after the disruptions occurs,
one or more of our critical service areas may not be able to
resume operations until the disruptions is over.
In all of the situations described above, EDIF expects to
resume operations within the specified time frames. However,
in the event that a business disruption results in a significant
loss of life at our headquarters or otherwise results in our
key employees being unavailable or unable to report to their
designated back-up facility, the recovery times described above
may be significantly increased. Furthermore, although we expect
to continue operating regardless of the type of disruption,
it is impossible to anticipate every scenario. It is, therefore,
possible that a significant business disruption could result
in EDIF deciding that we are unable to continue doing business.
In those situations, our plan provides procedures to help ensure
that our customers have prompt access to their funds and securities.
We are continuing to devote substantial resources to the enhancement
of our business continuity plan. In addition, we may enter
into agreements with other firms to perform certain clearing
and services functions on our behalf in the event of a disruption,
until we have the capability to resume performing those tasks.
Finally, we are working towards a target point of readiness
in which we will be able to resume operations within a time
period that is consistent with evolving industry standards
even if our key employees are unavailable.
EDIF’s business continuity plan is
subject to modification. We will promptly post information
about updates or modifications to the plan on our website.
You can also obtain updated information about the plan by
requesting a written copy by mail. All requests for updated
information should be sent to the following address: EDI
Financial, Inc., Attn: Michael Young, 12221 Merit Drive,
Suite 1020, Dallas, TX 75251.
SEC ORDER ROUTING DISCLOSURE
The Securities and Exchange Commission ("SEC") has
adopted Rule 11Ac1-6, which requires all brokerage firms to
make publicly available quarterly reports on their order routing
practices. In accordance with Rule 11Ac1-6, EDI Financial’s
order routing statistics are available for review by going
to our website at www.edifinancial.com.
If you have any questions regarding this information, you may
contact Michael Young at (214) 528-4090.
COMPLAINT NOTIFICATION
Please direct complaints to:
EDI Financial,
Inc., Attn: Michael Young, 12221 Merit Drive, Suite 1020, Dallas,
TX 75251. Telephone# (214) 528-4090.

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