Policies Regarding Customer Information

 MEB is committed to:

1) ensuring the privacy, confidentiality and security of customer information.

2) protecting the security and integrity of customer information from anticipated threats and hazards; and,

3) protecting customer information from unauthorized access or use. 

Accordingly, it is MEB’s policy that no employee, officer or Board member (“employee”) may share customer information with a non-affiliated third party except in accordance with the exemptions contained in Regulation S-P and described below.  It is also MEB’s policy to permit the sharing of customer information with its affiliates when for a valid business purpose

MEB shares customer information with non-affiliated third parties only when those parties are acting on our behalf in servicing customer accounts or in servicing MEB or as required by law.  These limited circumstances include our provision of customer information to:

• ·    insurance companies to underwrite an insurance policy to service customer accounts;

• ·    entities performing services on MEB’s behalf (such as administrators, etc.);

• ·     entities providing services for us to help market our products to our customers; and,

• ·     SROs and governmental or other legal agencies, as required by law.

When information is shared with third parties, they are legally obligated to maintain the confidentiality of MEB customer information and to limit their use of it to servicing MEB customer accounts, except as permitted or required by law. 

Under no circumstances will MEB sell customer information to any person or entity.

New Account Procedures

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 who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents. A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, partnership or trust agreement. U.S Department of the Treasury, Securities and Exchange Commission, FINRA, and Chicago Board Options Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance. If your identity cannot be established, our Firm may not be able to open an account or carry out transactions for you.

Business Continuity Plan

We are committed to providing reliable, trustworthy service that represents the best interests of our clients. The firm has developed a business continuity plan to protect our clients and employees in the event of an emergency or significant business disruption. The plan is designed to help prepare for securing employees' safety and firm property, making financial and operational assessments, promptly recovering and resuming operations, protecting the firm's books and records, and allowing our clients access to trading as soon as possible. The business continuity plan considers various scenarios that range in severity from a firm- or building-only disruption to an emergency situation on a local or regional level. For example, in the event our office locations are inaccessible, alternative locations are established and prepared to facilitate business operations. The firm has redundancies in place for its critical systems and believes that it would most likely be able to resume business within the same day as the disruption. Our goal in all situations is to return to normal business conditions as soon as possible, with minimal impact on our clients and employees. Notwithstanding the above, we cannot guarantee that for every disaster or business disruption, such plans will be successfully implemented or that such plans will be sufficient and appropriate to avoid, deter or mitigate the disaster or business disruption. Our business continuity plan is subject to change at any time without notice.

Payment for Order Flow and Order Routing Practices

MEB accepts payment for order flow. However, MEB’s policy with respect to order routing is that MEB will only route orders to an exchange, third-party vendor or order entry system that employs “smart router” technology, has a linkage system, or otherwise has the ability to confirm to MEB that the order will be executed at NBBO or better. MEB does receive and review Rule 606 reports from its third-party vendors and takes their execution statistics into account in determining whether to continue those relationships. If you have a question about the routing of a specific order, please contact MEB at 312-260-5541 and the information will be provided upon request.