RSM EquiCo Legal Information

LEGAL DISCLAIMER

RSM EquiCo is a tradename for RSM EquiCo, Inc. and its subsidiaries, which include: RSM EquiCo Capital Markets LLC (broker-dealer subsidiary licensed by the SEC and member FINRA, SIPC); RSM EquiCo Canada Inc. (limited market dealer registered with the Ontario Securities Commission); and EquiCo Europe Ltd (authorized and regulated by the Financial Services Authority). All capital markets activities are conducted by the broker-dealer subsidiaries. RSM EquiCo, Inc. and its subsidiaries are wholly owned subsidiaries of H&R Block.

ANTI-MONEY LAUNDERING AND ANTI-TERRORISM FINANCING POLICY STATEMENT

Under the USA Patriot Act and other regulations, financial services firms must establish a compliance program that includes policies and procedures to detect and report suspicious transactions to the government, as well as ensure compliance with the new laws. In accordance with the Act, RSM EquiCo has undertaken efforts to adhere to the Act’s policies and mandates.

We have dedicated ourselves to these policies and procedures in the fight against money laundering. As a firm with offices in the United States and abroad, we work closely with our employees to ensure compliance with all anti-money-laundering efforts. Further, we take steps to verify the identity of our clients and determine the source of funds in any given transaction.

RSM EquiCo will conduct its business in conformity with the highest ethical standards in the countries in which it does business, and will adhere to all laws and regulations pertaining to financial institutions. We believe it is vital for all RSM EquiCo associates to recognize actions that may be violations of applicable AML or counter-terrorism statutes, and to report any potential violation. Each associate is responsible for complying with all applicable AML laws and regulations.

RSM EquiCo and its subsidiaries remain committed to preventing our company from being used, in any manner, by persons engaged in transactions or other activities designed to conceal the true source of funds derived from criminal activity or used to fund criminal activity, including terrorism.

While preventing the misuse of RSM EquiCo by terrorists and other criminals is of vital importance, associates must not draw conclusions about customers and their banking activities based solely on the customers' religious affiliation, ethnicity, or national origin.

Money Laundering Prevention Policies and Procedures

Since criminals require financial services to support their illegal activity, financial institutions can play a key role in the detection and prevention of money laundering and the financing of terrorism. Knowledge of the customer provides a basis for understanding the general activities in which a customer would normally be expected to engage, thus giving an institution an opportunity to determine whether unusual activity should be reported as suspicious in accordance with applicable laws and regulations.

RSM EquiCo will:

Take reasonable steps to determine the true identity of all customers and beneficial ownership of accounts with RSM EquiCo;
Cooperate with law enforcement and regulatory agencies to the extent possible under all applicable foreign and domestic laws;
Comply with all AML and counter-terrorism laws and regulations to the extent possible under all applicable foreign and domestic laws;
Implement money laundering prevention programs, policies, and procedures that are consistent with the standards set out in the global money laundering prevention program and which address local risks and laws;
Comply with “know your customer" standards, including customer identification and verification procedures;
Develop and use technology to assist in the monitoring of transactions for the purpose of identifying and reporting suspicious activity and/or transactions;
Conduct independent audits to evaluate the our money laundering prevention programs and policies; and
Institute a global anti-bribery and anti-corruption program.

BUSINESS CONTINUITY STATEMENT

RSM EquiCo is dedicated to ensuring our ability to respond promptly and effectively to meet our clients' needs in times of disturbance.

RSM EquiCo maintains business continuity plans for itself and its subsidiaries that will allow us to continue critical business functions in the event of a business disruption. The procedures outlined in the plans have been developed following internal audits and discussions with our technology department and external consultants.

The primary goal of the RSM EquiCo Business Continuity Plan is to ensure that critical business practices can continue immediately following a business disturbance. The Plan defines critical functions, staff assignments, resource requirements, vital records, and alternate work-site locations that will enable us to restore business operations with minimal impact to clients or others.

As part of the plan, RSM EquiCo has identified applications critical to each of our business divisions. These applications are implemented in separate production and recovery data centers using industry-standard practices to copy data from the production site to the recovery site in real time.

Integral to our business continuity strategy is employee awareness and training; employees are aware of their roles and responsibilities when business activities are disrupted.

In the event of an incident rendering an RSM EquiCo location inaccessible, our strategy for continuing business is to first ensure the safety and security of all employees and then to continue critical business operations from a predefined alternate site. This alternate site is equipped to support the mission critical or ‘core’ business processes. The sites are far enough away to support our business should we experience a wide area disaster, but close enough for us to quickly relocate staff. Office supplies and equipment, along with forms and written instructions, are kept on site for use in an emergency.

To ensure confidence in our Business Continuity Plan, we conduct a number of tests each year. We execute our emergency notification procedures, review and update the business-impact analysis reports for each business unit, and perform the mission critical processes at the Disaster Recovery site on an annual basis. The RSM EquiCo technology team activates all of the hardware and software at the Disaster Recovery site at least twice a year, and more often if major changes have been made to the primary data center.

In addition, RSM EquiCo maintains contact with regulatory bodies such as the SEC, the Federal Reserve, and the Department of the Treasury to ensure that our business continuity plans meet or exceed industry requirements.

Although we have taken significant steps to develop and implement sound business recovery plans, we cannot guarantee that systems will always be available or recoverable after a disaster or significant business disruption. However, we believe that our planning for such events is robust and consistent with many of the best practices established within the industry. Any material changes to the above information will be available on our website.

If you have any questions, please feel free to contact Scott Ryder at 714-327-8687 or sryder@rsmequico.com.

LICENSING & REGULATIONS

RSM EquiCo Capital Markets is subject to the oversight of the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC).

Moreover, our management team is devoted to ensuring the firm adheres to the highest standards of ethical behavior.

While RSM EquiCo Capital Markets neither sells securities to the public nor engages in the issuance of securities, we provide investment banking services that often involve the transfer of securities. This occurs most often in M&A transactions where the acquisition strategy includes transfer of stock or in capital raising transactions involving the issuance of stock.

As a result, not only is the firm either regulated by or a member of the organizations mentioned above, but our dealmakers themselves are all licensed by the FINRA. Every RSM EquiCo Capital Markets employee who has dealmaking responsibilities is a registered representative and holds Series 7 and/or Series 63 licensing in all 50 states, as well as Washington, D.C. and Puerto Rico.

About the Regulatory Organizations

The Financial Industry Regulatory Authority (FINRA) is the world’s largest private-sector regulator of financial services. FINRA registers member firms, writes rules to govern their behavior, examines them for compliance and disciplines those that fail to comply. (http://www.finra.org/index.htm)

The Securities Investor Protection Corporation (SIPC) is a non-profit membership corporation established by Congress that insures securities and cash in customer accounts in the event of brokerage bankruptcy. (http://www.sipc.org)

The Securities and Exchange Commission (SEC) is the primary federal regulatory agency for the securities industry, whose responsibility is to promote full disclosure and to protect investors against fraudulent and manipulative practices in the securities markets. (http://www.sec.gov)

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