Policy Objectives

The purpose of the LPL Financial Identity Theft Prevention/Red Flag Policy is to define LPL Financial business units' responsibilities in detecting, preventing, and mitigating identity theft as required by the Federal Trade Commission (FTC) under the Fair and Accurate Credit Transactions (FACT) Act. The rule adopted by the FTC is referred to as the "Red Flag Rule."

Policy Scope

All employees, temporary workers, and contractors of LPL Financial and its affiliates are responsible for adhering to this policy.

Policy Owner

The LPL Financial chief security and privacy officer is responsible for administering this policy.

Responsibilities

LPL Financial takes seriously its regulatory responsibilities and all reports of identity theft will be investigated and acted upon, up to and including the involvement of law enforcement agencies, when needed.

All employees are required to receive regular training in identity theft prevention and red flag procedures. This training includes but is not limited to the new-hire training process.

Business units are responsible for maintaining procedures to identify red flags and monitor accounts that have been flagged as being potentially linked to instances of identity theft. Department management is responsible for performing regular identity theft risk assessments and updating related procedures, as necessary.

Examples of identity theft prevention procedures:

• Obtaining identifying documents from new clients
• Verifying information received from consumer reporting agencies and service providers
• Authenticating clients through the use of passwords and security personal identification numbers (PINs)
• Monitoring account transactions
• Verifying the validity of address changes

The executive risk committee assigns specific responsibility for implementation of the red flag program, approves material changes, and reviews staff reports of identity theft. The executive risk committee reports no less frequently than annually on status to the firm's Board of Directors.

Reporting Procedures

If you are a client of LPL Financial and feel you may be a victim of identity theft, please contact your financial advisor.

Any suspicion or incident of identity theft discovered by LPL Financial staff or advisors must be promptly reported to the ERM department via the security incident hotline at (866) 578-7011.