GREAT EASTERN MANAGEMENT

US PATRIOT ACT - AML/CIP POLICY

Great Eastern Management, Inc is an incorporated business in New York State, established in October of 1987.  We have one location of operation, currently in Westbury, NY. 

Our core business is creating a market for Certificates of Deposit between our nationwide network of bank (issuer) customers and our investor client base.  Our target customer base is comprised of FDIC member banks and NCUA member credit unions who invest in the jumbo CD market.  Other types of investor clients include school districts, municipalities, trade & professional associations, corporations, church groups, and individuals.

The two methods we use to establishing customer accounts are by directly soliciting Banks and Credit Unions using financial publications or by getting referrals from our existing Bank, Credit Union, or Government/Municipality Clients.  Great Eastern Management does not take any unsolicited calls from any type of investor.

As a registered Deposit Broker with the FDIC, Great Eastern Management has agreed to maintain permanent records of all CD trades done by our firm.  Upon request from the FDIC, we will provide them with information on any CD transaction set up by our firm.  Our registration as a deposit broker pertains only to transactions involving bank or credit union issued certificates of deposit.  Great Eastern Management does not and has never conducted any business involving stocks, bonds or any other registered securities, and as such, is not subject to any regulatory audits by the FINRA or SEC.

Great Eastern Management has established a policy to abide by the identification guidelines set forth in the US Patriot Act effective October 1, 2003, pertaining to all CD accounts that we refer to any bank or credit union.  According to the Patriot Act guidelines, any investor account that is an FDIC registered bank or an NCUA registered Credit Union is considered to be an “Account” and is exempt from Patriot Act identification requirements.

Any other investor that is not exempt, including school districts, municipalities, trade associations or any other incorporated business is considered a “Customer”, and is therefore required to comply with the identification policies described in the Patriot Act. These accounts will provide Great Eastern Management with signed copies of their Articles of Incorporation and/or Corporate Resolution.  These documents will contain the signatures of all of the officers of the Corporation with their titles, and will describe who all of the eligible signers are for the account.  These documents will be sent to the bank issuing the CD along with our regular account set up information.