First Ballantyne, LLC collects nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms
• Information about your transactions with us or others
• Information we may receive from a consumer-reporting agency

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law.

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.

First Ballantyne, LLC restricts access to your personal and account information to those employees who need to know that information to provide products or services to you. First Ballantyne, LLC maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information. We may disclose all of the information we collect, as described above, to companies that perform clearing services on our behalf or to other financial institutions with whom we have service agreements.

Protecting your privacy is an ongoing process. As technology continues to advance, First Ballantyne, LLC will continue to evaluate its security standards and procedures associated with protecting your privacy. Nothing is more important to us than our clients’ trust and confidence, and we will take whatever steps necessary to maintain the security of our professional relationships.

This policy will remain in effect until further notice.
Dated: December 31, 2008