Privacy Policy

The Securities and Exchange Commission recently enacted Regulation S-P, commonly referred to as “The Privacy Rule”, in response to the Gramm-Leach-Bliley Act. This rule requires all broker-dealer firms to provide all of its customers and consumers a disclosure statement, outlining the Firm’s procedures and policies regarding the safeguarding of non-public personal information that is obtained during the normal course of business.

CCM Securities understands your privacy is important and has always been committed to maintaining your confidentiality. This notice will help you understand what types of non-public personal information, information about you that is not publicly available we may collect, how we use it, and how we protect your privacy.

We recognize that you expect your personal information to be handled in a professional and confidential manner. We have adopted the following policies to safeguard your privacy and to explain the circumstances, under which we may collect, maintain and use any non-public personally identifiable information that you may provide us. We collect information about you to help us serve your financial needs, provide customer service, offer new products or services, and fulfill legal and regulatory requirements. The type of information we collect may include:

• Information we receive from you on applications or other forms (i.e. your name, address, social security number, assets and income).
• Information about your transactions with us or others (i.e. your account balance, payment history, or parties to transactions).
• Information that we receive from a consumer reporting agency (i.e. your creditworthiness and credit history)

We do not share non-public personal information about you with unaffiliated third parties with whom we have no contractual business relationship for their independent use unless (1) you give us permission, (2) it is necessary to complete a transaction on your behalf, (3) it is necessary to protect against fraud, comply with a subpoena or other court order and is otherwise required or permitted by law. We do not sell information about you to outside unaffiliated companies.

Further, we restrict access to your personal and account information to those employees who need to know that information to provide products or services to you and maintain strict physical, electronic, and procedural safeguards to guard your non-public personal information.

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. We reserve the right to change these privacy policies at any time. You will receive appropriate notice of changes to our Privacy Policy. You may opt-out of the disclosure of non-public personal information to a non-affiliated third party by giving us notice in writing or e-mail.

For more information, to find out what personal information of yours we have collected, or to update your personal information, please contact CCM Securities at 646.367.2634.

Business Continuity Summary

As part of our ongoing commitment to our clients, this will serve to provide an overview regarding the CCM Securities (”CCM”) Business Continuity Plan (”BCP”). The CCM BCP is reviewed and tested at different intervals, and is tested annually. Modifications and updates are made to incorporate any material business change or regulatory requirement. This overview is an attachment to the firm’s BCP.

Business Continuity Components

CCM Securities has evaluated the impact of business interruptions resulting from various events including but not limited to loss of facilities and resources. The BCP was developed by identifying methods to protect and restore critical business processes, records, data and systems to allow customers to transact business. CCM Securities and TJM Investments have entered into a Commission Sharing Agreement in which CCM Securities will introduce certain customers to TJM Investments. As part of this agreement, TJM Investments has contracted with Merrill Lynch Corporation (MLPCC) as our third party provider to back up their important records in a geographically separate area, for the protection and restoration of customer records, transactions, custody of funds and securities and operating systems. The third party providers have in place, a business continuity plan with system redundancy and back-up facilities.

Recovery Plan

In the event of a business interruption, CCM has established plans with teams that will activate to address an immediate response to the incident. The management will continue to work to resolve any interruptions caused by the situation beginning at the initial time of the incident until the matter is resolved.

The data recovery plan includes maintenance of redundant real-time system facilities. The staff and workspace recovery plan includes the relocation of critical personnel to alternative sites.

Whatever the event, our BCP is designed to enable the firm to be operational within 24 hours or less assuming that third party providers and industry critical systems are operational as well.

Contact Us

Call the CCM Chicago Office at 312.577.5601 or go to our website at http://www.ccmfinancialgroup.com.

If you cannot access us at any of those means, then you should contact one of our clearing firms, GSEC at 212.357.2266, JPMCC at 212.552.1919 and MLPCC at 312.347.3600 for liquidating orders, funds requests and transfers.

CCM will continue to promptly post modifications and updates to the BCP overview on the website.

Business Purpose

This overview of CCM’s BCP is designed to satisfy the disclosure requirements of FINRA rule 4370 which was formerly NASD Rules 3510 and 3520 approved by the Securities and Exchange Commission on April 7, 2004.

SIPC Notification

All customers are advised that information about SIPC, including the SIPC brochure, may be obtained by contacting SIPC. SIPC may be contacted by phone, email or regular mail:

Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215
Tel: (202)371-8300
Fax: (202)371-6728
Email: asksipc@sipc.org
For more detailed information please visit the SIPC website at www.sipc.org

FINRA Notification (Broker Check)

FINRA’s public disclosure program toll free hotline number is (800)289-9999 and FINRA’s website address at: http://brokercheck.finra.org/Support/TermsAndConditions.aspx

Customer Identification Program (CIP Notice)

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person or company who opens an account with CCM Securities.

What this means for you: When you open account, we will ask for the name of your entity, address, tax identification number and other information that will allow us to identify you and conduct proper due diligence regarding Anti-Money Laundering. We may also need to see your articles of incorporation, partnership agreement or other identifying documents.

If you require further inquiry regarding this CIP Notice, please visit the following link on FINRA.org

http://www.finra.org/web/groups/industry/@ip/@issues/@aml/documents/industry/p011398.pdf