IMS Securities, Inc. Member FINRA/SIPC IMS Financial Advisors, Inc. INDEPENDENT REGISTERED REPRESENTATIVE ANNUAL CERTIFICATION The Firm and you are subject to a multitude of laws and regulations governing our industry. Regulators' rules require that you provide certain information to the Firm. Please complete the following, providing complete explanations where necessary. If your response changes at any time in the future, you must inform the Firm immediately. For any YES answers please provide details. RR/IAR Name (printed): U-4 Updates and Affiliations 1. Have you ever been the subject (whether named or not) of any oral or written customer complaint, arbitration, or lawsuit, or do you have a copy of any complaint that has not been previously submitted to the Firm? If yes, please explain. 2. Have you been found by the SEC, CFTC, other Federal or state regulatory agency (including securities, banking, insurance), foreign financial regulatory authority, National Credit Union Administration or self regulatory organization (such as FINRA, MSRB, other exchanges) to have violated their rules or have any of these agencies imposed a final order that bars or otherwise disciplines you? 3. Have you ever been involved in any investment related investigation, civil litigation, arbitration or administrative proceeding by any of the above listed agencies? 4. Have you ever had any unsatisfied judgments or liens against you? 5. Have you or any organization that you controlled ever filed for bankruptcy (voluntary or involuntary), or entered into a compromise with creditors? 01/2015 10205 Westheimer Rd, Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 1
6. Have you ever been arrested, arraigned, charged or indicted for any criminal offense (except for minor traffic violations)? 7. Have you ever been convicted of, or pled guilty or no contest to any felony or misdemeanor in a domestic, foreign or military court? 8. Have you ever been convicted of, or pled guilty or no contest to any misdemeanor involving investments, any investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting or extortion? 9. Do you or your immediate family members conduct business with or are employed by an entity that does business with the firm? 10. Do you or your immediate family members have any relationships with any of the products or investment managers recommended by the firm? 11. Are you or any of your immediate family members employed by a publicly traded company? If YES, please list family member name, occupation and employer. 12. Are you or any of your immediate family members an officer or director of any corporation? If YES, list the corporation name and explain whether you hold 5% or more of the outstanding stock. Outside Brokerage Accounts, Outside Business Activities, Private Securities Transactions, Contributions 13. Do you or your spouse, your dependent children or any other relative or person to whom you provide financial support have any accounts or an interest in a securities account at any other brokerage firm or financial institution? If YES, please list all accounts including the name of the other broker dealer or financial institution, account number, and registration name on the account. It is not necessary to list direct investments in open end mutual funds, unit investment trusts, or variable contracts or accounts limited to such securities. 01/2015 10205 Westheimer Rd, Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 2
14. While associated with the firm, have you engaged in ANY private securities transactions? If yes, explain. 15. Are you engaged in any outside business activity, and/or do you serve as an officer, director, or employee of another business organization (compensated or not)? Outside activities include outside employment, acting as a general partner, finder, director, referrer, or any activity outside your usual responsibilities at IMS including non-variable insurance sales. Compensation includes salaries, director's fees, referral fees, stock options, finder's fees, and anything of present or future value. If YES, please list all activities. 16. If YES to question 15: Do you market or advertise any of your outside business activities in any way, including a website or any other form of social media? If YES, list website address and/or marketing tool. N/A 17. If YES to question 15: Do you have a designated email address that is associated with this Outside Business activity? If YES, list the email addresse(es). N/A 18. If YES to question 17: Have you made arrangements with SMARSH to capture this email address? N/A 19. In the last 12 months, have you made any political or charitable contributions? Charitable contributions which were made to a customer's organization or on behalf of a customer. If YES, please list the name of person/organziation and contribution amount. Sales and Business Practices 20. Do you handle any customer accounts on a discretionary basis? If YES, provide a list of accounts or attachment including custodian, acct numbers and client names. 21. Do you ensure that any securities products that you recommend to your clients are suitable in light of their investment objectives, financial situation and liquity needs? If, explain. 22. Do you maintain a blotter with every transaction processed? If, explain. 23. Do you maintain the IMS Gift Log in accordance with the policy on gifts and gratuities? If, explain. 24. Do you obtain appropriate documentation in connection with a client s replacement of one insurance product for another? If, explain. 25. Do you promptly deliver all issued variable product contracts to clients when delivered to you? If, explain. 01/2015 10205 Westheimer Rd, Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 3
26. Are any customer accounts (other than your personal accounts) addressed to forward mail to your attention or the Firm s attention? If YES, provide a list of account numbers and names. 27. Have you accepted cash from customers? If YES, under what circumstances? 28. Have you borrowed from or loaned money to any of your customers (other than your personal loans from banks or other financial institutions available on the same terms to the general public)? If YES, provide the date, customer name, purpose, and amount. 29. Have you acted or do you currently act as a trustee, custodian or have POA of any account, money, securities, or stock powers for any customers? If YES, list account numbers and names. 30. Do you have any accounts where you accept orders from someone other than the principal owner or person with designated authority for the account (including accounts where the husband is entering orders for a wife s account)? If YES, please list. 31. Have you in any way guaranteed or offered to guarantee a customer against loss in any securities transactions during the past year? If YES, indicate the date and circumstances. 32. Have you shared, directly or indirectly, in the profits or losses of an account of a customer or in a transaction with or for a customer, including any accounts where you are a joint owner with someone not related to you, during the past year? If YES, provide the date, customer name, details of the arrangement and your relationship to the customer. 33. Have you entertained any union-affiliated individual or made any gift, payment or loan, direct or indirect, of money or other things of value (including reimbursed expenses) or any promise or agreement to make such payments, to any labor organization (union) or officer, agent, shop steward or other representative or employee of a labor organization? If YES, identify the recipient, the amount and the nature of the entertainment, payment, loan, gift, etc. 34. Do you have any accounts where the customer is employed with another securities firm or a regulator (FINRA, exchanges, etc)? If YES, list customer name, acct number, employer name and position held at the other firm. 35. While associated with the firm have you sold any securities or insurance product(s) to a client who resides in a state in which you are not licensed to sell that product? 01/2015 10205 Westheimer Rd, Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 4
36. While associated with the firm, have you sold any securities products to a client when you have not been licensed by the FINRA to sell that product? 37. Are you aware that it is a violation of both federal and state securities laws for commissions to be paid or otherwise directed to individuals or firms who are not properly licensed and if they are licensed, the commissions must be directed through IMS? 38. Do you sell Equity Indexed Annuities or Index Universal life products? If YES, list companies used. 39. Do you certify that you have access to the IMS Written Supervisory Manual and/or Investment Advisory Manual and understand all policies and procedures including the following: Firm s policy regarding Insider Trading Firm s policy regarding Electronic Communications Firm s policy regarding Money Laundering Firm s policy regarding Ethics (available on IMS website) Firm s policy regarding Communications with the Public Firm s policy regarding Social Networks Communications With The Public 40. Do you advertise, write research reports or sales literature, or conduct seminars for customers or prospective customers? If YES, please explain. 41. Are you or do you anticipate using electronic communication systems, such as Website, social media, radio, television, etc. for advertising or soliciting business? If YES, please explain. 42. Has all advertising, sales literature and correspondence used during the year been approved by a principal of the firm prior to use and maintained in the appropriate file(s)? If NO, explain. 43. Do you have additional email accounts (personal) other than your IMS approved email account? List ALL. 44. Have you submitted copies of all outgoing customer correspondence for approval, including fax transmissions? If NO, please explain. 01/2015 10205 Westheimer Rd, Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 5
45. Do you use social networking sites (ex. Facebook, Twitter, LinkedIn, etc) for personal or business purposes? If YES, please list sites and indicate the purpose (personal or business). 46. Do you have any kind of professional designation(s)? If YES, please list. 47. If marked YES above, have you completed all continuing education requirements to maintain the license(s) active? If NO, please explain. te: Proof must be available upon request. N/A Other 48. Do you have any staff (full-time, part-time, temporary and/or contract) working in your office? If YES, please name staff members. 49. Does your staff solicit transactions or new accounts, render investment advice, make recommendations to customers or effect transactions in securities on your behalf? If YES, explain. 50. Does your staff use your IMS approved email account and/or personal email account to correspond with individuals on your behalf? If YES, please explain. 51. Do you, your spouse or children have any accounts held at IMS through Pershing or Southwest Securities? If YES, please list account name, account number and clearing firm name. 52. Please list ALL personal and business bank accounts which you are associated with, including account registration name, financial institution and account number. Signature Printed Name Date 01/2015 10205 Westheimer Rd Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 6
Please use the following page if you need additional space to answer any of the questions on the annual form. Please use this section if you need additional space to answer any of the questions on the annual form. RR/IAR Name (printed): Question # Details 01/2015 10205 Westheimer Rd, Suite 500 * Houston, TX 77042 * (713) 266-2993 Annual Certification - 7