PRIVACY POLICY

CFS Policy on Protection of Consumer Information and Records

Carolina Financial Securities, LLC (CFS) is a member of FINRA.  FINRA Notice to Members 00-66 specifies that its members comply with Regulation S-P of the SEC, “Privacy of Consumer Information” (“Privacy Act”).

In part, the Privacy Act requires that each broker-dealer adopt policies and procedures that address the protection of customer information and records.

This makes up CFS’s Policy on Protection of Consumer Information and Records.

CFS receives confidential information in the course of its business.   This includes subscription documents and questionnaires that have been filled out by its investors.  These may contain social security numbers, home addresses, annual income, net worth, educational background, Employer Identification Numbers, and other related data that is essential for CFS to have in determining the suitability of the investors to invest in private capital.

It is the policy of CFS to keep all such records in utmost confidence.  It is also CFS policy not to release such information to any third party.  CFS has no affiliates who would need or want such information.  CFS’ employees are initially and continually alerted to the fact that CFS obtains confidential information about its investors which must be held in the strictest confidence.

CFS does not disclose any nonpublic personal information about its investors to anyone, except as permitted by law.

Carolina Financial Securities, LLC restricts access to anyone’s personal and information to those CFS employees who need to know that information to provide products or services to its customers.  Carolina Financial Securities, LLC maintains physical, electronic, and procedural safeguards to guard customers’ nonpublic personal information. These safeguards include keeping all confidential information within premises that are locked or manned at all times, maintaining a strict confidentiality policy, and discussing CFS’ confidentiality policies at its semi-annual continuing education meetings.

BUSINESS CONTINUITY PLAN

CFS Business Continuity Statement

As a member of FINRA, Carolina Financial Securities, LLC (CFS) is bound by all FINRA and SEC rules and regulations.  FINRA Rule 4730 specifies that each member firm must maintain a plan with adequate procedures to ensure that in the face of an emergency or significant business disruption,  the member firm will be able to meet all existing obligations to customers .

In an effort to comply with this rule, as well as an attempt to ensure that we consistently provide the highest level of service possible to our customers, without falter, CFS has developed a Business Continuity Plan that we believe is designed to permit us to deliver virtually uninterrupted service to our customers in the event of an emergency.

One of the greatest strengths of CFS to achieve this level of assurance is the geographic disparity of our personnel.  Only a small portion of our firm representatives are located at our headquarters in Brevard, NC.  The remainder of firm personnel are spread out in other parts of North Carolina, Georgia, Connecticut, and California.  In the event of an emergency central to our headquarters, CFS will first attempt to move operations to the home of Bruce Roberts, firm President.  If the emergency is dramatic enough to impact the entire area and render us without local access to the necessary resources to effectively continue business, our outside personnel are equipped with the skills and abilities necessary to continue operations nearly seamlessly.  The use of a calling tree will immediately be implemented to coordinate deployment of firm personnel to the established business location.

All CFS data are backed up remotely on a weekly basis.  During an emergency, once a physical location for conducting business has been established and employees have been located and notified, the most recent data backup will be transferred to that location.  These data include digital copies of all customer closing documents.  CFS does not maintain custody of customer funds or securities and all customers are provided with complete sets of closing documents for each transaction that they initiate.  The customer’s own copy serves as an additional backup to the remote data backup.  At the off-site location that is established, CFS will procure necessary communications, digital or analog, to contact customers and issuers in order to resume operations.