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Regulatory Disclosures

Regulatory Disclosure Statement

Efficient Markets, LLC (“Efficient Markets” collectively with Efficient Markets, LLC’s affiliates, parent companies, subsidiaries, and agents) Regulatory Disclosures:

The U.S. Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority, Inc. (“FINRA”), and other regulators have various rules and regulations that require broker-dealers to provide certain disclosures of policies and procedures regarding its business continuity & succession plan and privacy policy. In accordance with these mandated regulatory requirements and industry best practices, and to give its clients transparency into those policies and procedures, Efficient Markets, LLC (“Efficient Markets” or the “Firm”) is providing the following regulatory disclosures to its clients.

Vulnerability Disclosure Policy

As trusted broker and partner, Efficient Markets takes seriously our responsibility to protect customer information, including financial and personal information, from unwarranted disclosure.

Should a vulnerability be discovered, Efficient Markets encourages reporting of the vulnerability to the Efficient Markets Security team to afford Efficient Markets the opportunity to remediate the findings.

You must comply with all applicable federal, state, and local laws in connection with any security research activities.

Reporting a Vulnerability or Software Bug to the Firm

Bug reports, including vulnerability reports, may be sent to devteam@efficientmarkets.com. Reports should include a description of the location and potential impact of the issue along with detailed descriptions of the steps required to reproduce the observed behavior. Please contact us prior to sending any sensitive or potentially dangerous information via email, and we will provide an alternate exchange.

Vulnerability Disclosure

Efficient Markets is committed to patching vulnerabilities within 90 days or less and disclosing vulnerability details when remediation is complete. Although we do not require coordinated disclosure, we prefer and encourage coordinated disclosure as responsible security practice.

Efficient Markets may share vulnerability reports with US-CERT, or affected upstream vendors or projects. We will not share personal information or information about our communications with vulnerability reporters without permission.

Privacy Policy Disclosure Notice

We at Efficient Markets, LLC, respect your privacy. We are committed to maintaining the privacy and security of your personal and financial non-public information (NPI). We adhere to confidentiality standards designed to protect your privacy. Our Privacy Policy applies to both past and current Registrants of the Firm.

Federal law established privacy guidelines, effective July 1, 2001, requiring advanced privacy policy notice to Registrants. The advance notice was designed to give Registrant’s the right to “opt out” of Efficient Markets’ disclosure of certain information to third parties.

We do not sell or disclose your personal information to anyone:

  • Efficient Markets does not disclose non-public personal information to third parties which would trigger this right to “opt out”, so in effect our Registrants are automatically opted out.

We collect your non-public personal information from the following sources:

  • Information you have given us, such as your when you complete your online registration and other information you provide in writing or orally to the Firm. This data is known as non-public personal information (e.g., name, address, telephone #, assets, income, credit reports/scores, driver’s license and tax ID numbers, etc.).
  • Information the Firm may receive from third parties, such as banks, regarding your transaction with us.

We only share non-public personal information in accordance with federal law and under the following circumstances:

  • When Efficient Markets is required to provide services you requested.
  • We may share information with affiliated or interested parties for the intended purpose only, including outside compliance and regulatory consultants, independent contractors for regulatory purposes and those that help us conduct our business, such as IT professionals, once we have entered into contracts with these companies that include a confidentiality clause (or obtain a separate executed Confidentiality Agreement) which prohibits them from using the information provided for their own purposes and requires them to keep the information confidential.
  • When you have specifically authorized and directed us to do so.
  • Where we believe in good faith the disclosure is required or permitted by law; such as pursuant to a request for information from the Federal Bureau of Investigation (FBI), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC); or other parties under Court Order or Subpoena.
  • When the Firm’s books and records are examined by federal or state regulators.

Confidentiality and Security:

  • We restrict access to non-public personal information about you only on a “need-to-know” basis to those employees or service providers that provide products or services to Efficient Markets. We maintain strict physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information.
  • We keep all personal information about Registrants in locked storage and provide secure removal of unusable documents containing Registrant non-public information by shredding the documents.
  • All mail is received in a USPS approved stand-alone keyed lock box kiosk located on the building property. Only authorized personnel may collect and distribute incoming mail.

Efficient Markets reserves the right to change these policies at any time and will make the revised document available on its website as changes occur.

Your review of this notice does not require any response from you. However, should you have any questions about this notice, please contact us at:

Efficient Markets, LLC
ATTN: Compliance Department
1902 Washington Avenue, Suite A
Houston, TX 77007
Email: info@efficientmarkets.com
Phone: (877) 351-4488

Our Business Continuity & Succession Plan (“BCP”)

The Firm has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us

If, after a significant business disruption you cannot contact us as you usually do at (877) 351-4488, you should call our alternative number (806) 686-1866, email info@efficientmarkets.com or go to our website at https://www.efficientmarkets.com/.

Our Plan Details

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the Firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our Business Continuity and Succession Plan addresses:

  • Data backup and recovery;
  • All mission critical systems;
  • Financial and operational assessments;
  • Alternative communications with customers, employees, and regulators;
  • Alternate physical location of employees;
  • Critical supplier, contractor, bank and counter-party impact;
  • Regulatory reporting;
  • Death, incapacity or unavailability of key personnel; and
  • Assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our Firm, a single building housing our Firm, the business district where our Firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our Firm or a building housing our Firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 3 days. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one week. In either situation, we plan to continue in business, transfer operations to another location if necessary, and notify you through our website https://www.efficientmarkets.com or our customer emergency number (806) 686-1866 on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

For more information If you have questions about our business continuity planning, you can contact us at (877) 351-4488.

Required Registrant Identifying Information

Prior to accepting a Registrant Buyer or Seller participation in either we require the following information from you:

  • Full legal name
  • Physical address
  • Contact phone number
  • Contact email address
  • Financial qualifications
  • Investment experience and objectives
  • Oil and gas industry experience
  • Social security number or employer identification number,
  • We may also request a copy of your valid driver’s license or passport or any legal document with a photograph of you that has been issued by a state or federal authority.

Complaints

In accordance with SEC Rule 17a-3(a)(18)(ii), please be advised that any complaints may be directed to the following:

Efficient Markets, LLC
ATTN: Compliance Department
1902 Washington Avenue, Suite A
Houston, TX 77007
Email: info@efficientmarkets.com
Phone: (877) 351-4488

For More Information

If you have any additional questions, please contact our Compliance Department at (877) 351-4488.