Policy Objectives

The Investment Center, Inc. ("The Investment Center"), an introducing broker-dealer located in Bedminster, New Jersey, has developed an Identity Theft Prevention Program, ( the "Program")  which is designed to detect, prevent, and mitigate identity theft in connection with the opening of covered accounts or any existing covered account. This Program is intended to fulfill both the letter and spirit of the Identity Theft Red Flags Rule as outlined pursuant to Sections 114 and 315 of the Fair and Accurate Credit Transactions Act ("FACT Act").  The rule adopted by the FTC is referred to as the "Red Flag Rule."

Policy Scope

All employees, temporary workers, and contractors of The Investment Center and its affiliates are responsible for adhering to this policy.

Responsibilities

The Investment Center takes seriously its regulatory responsibilities and all reports of identity theft will be investigated and acted upon, up to and including the involvement of law enforcement agencies, when needed.

All employees are required to receive regular training in identity theft prevention and red flag procedures.

Various departmental units are responsible for maintaining procedures to identify red flags and monitor accounts that have been flagged as being potentially linked to instances of identity theft. Department management is responsible for performing regular identity theft risk assessments and updating related procedures, as necessary.

Examples of identity theft prevention procedures:

• Obtaining identifying documents from new clients
• Verifying information received from consumer reporting agencies and service providers
• Authenticating clients through the use of passwords and security personal identification numbers (PINs)
• Monitoring account transactions
• Verifying the validity of address changes

Reporting Procedures

If you are a client of The Investment Center and feel you may be a victim of identity theft, please contact your financial advisor.

Any suspicion or incident of identity theft discovered by The Investment Center staff or advisors must be promptly reported to our Compliance Department at (800) 345-1841.