Identity Theft Prevention Plan (ITPP)

The Firm maintains an Identity Theft Prevention Plan (“ITPP”) that is intended to protect our clients and their accounts from identity theft and to comply with the FTC’s Red Flags Rule. The ITPP addresses identification of relevant identity theft Red Flags for our Firm, detecting those Red Flags, responding appropriately to any that are detected to prevent and mitigate identity theft, and updating our ITPP periodically to reflect changes in risks.

To identify relevant identity theft Red Flags, our Firm assessed these risk factors:

• The types of covered accounts introduced to our clearing firm,
• The methods provided to open or access these accounts, and
• Our clearing firm’s previous experience with identity theft.

Our Firm also considered the sources of Red Flags, including identity theft incidents our clearing firm has experienced and how they changed identity theft techniques as they became aware of new risks, and applicable supervisory guidance of both our Firm and our clearing firm.

In addition to developing responses to Red Flags once they are identified, our Firm has also taken proactive measures to mitigate the likelihood of identity theft. Some of those proactive measures may include, but are not necessarily limited to, the following:

• Securing front-end system access,
• Physical and logical access controls,
• Secured vendor key-locked on-site shredding bins,
• Disposal of decommissioned electronic media, and
• Internal education to our staff and associated persons.

The Firm’s ITPP also provides for on-going associate education and training and oversight of vendors who may receive confidential information.

The Firm’s ITPP is subject to continual change as we assess the ongoing needs of our clients and changing business environment in which we operate. The Firm’s ITPP is periodically reviewed by Management. Questions regarding the Firm’s ITPP may be directed to our AML/ITPP Compliance Officer at WestPark Capital, Inc., 1900 Avenue of the Stars, Suite 310, Los Angeles, CA 90067 or via telephone at (310) 843-9300.