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Policies and Procedures

Statement of Policies, Procedures and Rules Governing Customer Accounts
THIS DOCUMENT CONTAINS IMPORTANT TERMS AND CONDITIONS THAT APPLY TO BROKERAGE ACCOUNTS MAINTAINED WITH FBRDirect AND CARRIED BY NATIONAL FINANCIAL SERVICES LLC (NFS), A FIDELITY INVESTMENTS COMPANY THE TERMS AND CONDITIONS CONTAINED HEREIN SUPERSEDE AND REPLACE ANY CONFLICTING TERMS AND CONDITIONS CONTAINED IN ANY PRE-EXISTING AGREEMENTS OR DOCUMENTS, INCLUDING BUT NOT LIMITED TO CUSTOMER ACCOUNT AGREEMENTS, MARGIN AGREEMENTS, AND OPTIONS TRADING AGREEMENTS PREVIOUSLY ENTERED INTO BETWEEN YOU AND FBRDirect. PLEASE READ THIS STATEMENT CAREFULLY AND RETAIN IT FOR YOUR FUTURE REFERENCE. YOUR ACCEPTANCE OF THE TERMS AND CONDITIONS CONTAINED IN THIS STATEMENT OF POLICIES, PROCEDURES AND RULES WILL BE INDICATED BY YOUR DECISION TO CONTINUE CONDUCTING BUSINESS WITH FBRDirect.

FBRDirect where it appears in this document shall mean FBRDirect, its affiliates, and agents, including any agents with whom FBRDirect has entered into agreements to service customer accounts.


ACCOUNT ACCEPTANCE
FBRDirect and National Financial Services LLC (NFS), a Fidelity Investments Company, may at their discretion decline any account for any reason.

PROCEDURES REGARDING ACCEPTANCE OF CUSTOMER’S ORDERS
Customer’s instructions to buy or sell securities may not constitute acceptance by FBRDirect simply because of receipt of instructions by FBRDirect or its designated representative; such acceptance procedures may cause delays. FBRDirect does not accept customer instructions to buy or sell securities received by e-mail. In certain instances and at FBRDirect's discretion, orders are deemed accepted only after they have been approved by FBRDirect. FBRDirect will not be held responsible for delays in accepting customer’s orders to buy or sell securities resulting from the need to obtain such prior approval before a particular order may be entered. FBRDirect may at its discretion, at any time, and without prior notice, prohibit your ability to enter any order and to initiate securities transactions, for any reason. In periods of extreme market volatility and heavy trading volume, FBRDirect reserves the right, at its discretion, at any time, for any reason, to limit and restrict the types of orders it will accept from its customers. Also in such periods, various exchanges may limit the types of orders they will accept. For example, under certain unusual circumstances, FBRDirect may decline to accept Good ‘Til Canceled orders ("GTC") and Stop Loss orders. Further, FBRDirect retains the right, at its discretion and without prior notice, to prioritize the entry of customer orders, for example giving market orders a higher priority than limit orders. From time to time, National Financial Services LLC (NFS), a Fidelity Investments Company may receive remuneration for directing orders to a particular broker/dealer or market place for execution. Such remuneration is considered compensation to National Financial Services LLC (NFS), a Fidelity Investments Company and the source and amount of any compensation received by National Financial Services LLC (NFS), a Fidelity Investments Company in connection with your transaction will be disclosed upon request. FBRDirect may record telephone conversations to assure accuracy and verify data concerning securities transactions, and may verify any information supplied by customers. Customer price limit orders placed in increments not accepted by the primary marketplace will be automatically adjusted to the nearest acceptable price that is more beneficial to the customer upon execution. Buy orders placed in Individual Retirement Accounts may be adjusted based upon available funds in the account. This adjustment may take the form of either a limit on shares ordered or a limited price stipulation, even on market orders, at FBRDirect's discretion. Accounts with regulatory restrictions on margin purchasing may be restricted to one day only buy orders and/or limit buy orders may be restricted to approved funds available.

POLICY REGARDING CONTROL OR RESTRICTED SECURITIES
Prior to your placing any order in connection with any securities subject to Rule 144 or 145 (d), under the Securities Act of 1933, you must advise FBRDirect of the status of the securities and furnish FBRDirect with the necessary documents to clear legal transfer. There may be delays involved with the processing of control or restricted securities, and neither FBRDirect nor National Financial Services LLC (NFS), a Fidelity Investments Company will be responsible for any losses caused directly or indirectly by such delays. FBRDirect may require that control or restricted securities not be sold or transferred until they clear legal transfer. You further agree not to tender any such restricted securities as collateral for any obligations you may owe.

DEPOSIT MAINTENANCE OF EQUITY/ADVANCE PAYMENT
FBRDirect requires an initial deposit of $10,000 cash (or $2,500 for an IRA) or equivalent securities to open an account. In addition, FBRDirect requires that customers maintain a minimum of $10,000 equity in each account.

Generally, FBRDirect’s policy is that purchase orders are accepted only if "available funds" greater than or equal to the purchase amount are on deposit in the account prior to trade date. Sell orders (other than orders to sell short) are generally accepted only if the subject securities are long in the account in good deliverable form prior to trade date. However, all orders for purchase or sale of securities that you authorize shall be processed and/or executed with the understanding that an actual purchase or sale is intended and it is your obligation and intention in every case to pay for any purchase or deliver any security to cover all sales on or before settlement date. Cash accounts do not limit your losses or liability to the funds available in your account. See Customer Agreement for additional details.

GENERAL POLICY REGARDING THE SETTLEMENT OF SECURITIES TRANSACTIONS
You are responsible for insuring that payment is received and that securities are received in accordance with the aforementioned policy. You should be aware that delays in mail service are common and that policies regarding the extension of credit are universal throughout the securities industry and are governed by various regulatory authorities. FBRDirect must, without exception, pay for purchases made on your behalf by settlement date (which is three business days from the date of the transactions for most securities and the next business day for options) regardless of whether or not we have received your payment. After you place an order to buy or sell securities and a trade execution in accordance with your order occurs, you are obligated to make your payment or deliver securities no later than settlement date. In all instances, you will be at risk and liable for any loss incurred. When payment or securities are not received by FBRDirect within the prescribed period, FBRDirect must either liquidate or buy back the securities for your account and risk or cancel the transaction at the discretion of FBRDirect or file for an extension of credit from an appropriate regulatory agency, provided there is an acceptable reason for the delay in payment or receipt of securities. A fee of $15 per extension request will be charged. In addition, the number of extension requests that FBRDirect can make on behalf of a customer is limited. Should a regulatory agency determine that there have been too many extension requests for a given customer in a particular time period, they may restrict your account. In instances where FBRDirect does not receive payment by settlement date, FBRDirect reserves the right, at its discretion, to charge the account a late payment fee calculated from settlement date until the clearance of the debit as computed at the then prevailing interest rate charged by FBRDirect on cash debit balances. Please indicate your account number on all checks and securities sent to FBRDirect and make certain that all securities are properly endorsed to National Financial Services LLC (NFS), a Fidelity Investments Company. If any securities are delivered to FBRDirect by you, or otherwise held in your account for your benefit, you are obliged to notify FBRDirect in writing prior to placing any order if such shares are unregistered, subject to restrictions on resale, or are otherwise subject to any restriction whatsoever on sale or transfer. You agree not to tender any such securities as collateral for any obligation that you may owe FBRDirect. The same obligation of immediate written notification shall arise where you are, or have become, an officer, director or 5% or greater shareholder of any publicly held company within the last two years. Your failure to notify FBRDirect of any of the circumstances or conditions set forth above will result in your agreeing to indemnify and hold FBRDirect, their officers, directors, employees and agents harmless from any resulting liability or loss, financial or otherwise, which FBRDirect may suffer as a result of your failure to properly notify FBRDirect in this regard.

PROCEDURES REGARDING GOOD UNTIL CANCELED ORDERS
Unless otherwise stipulated, all orders are day orders only. Good ’til Canceled ("GTC") or open orders, as they are commonly referred to, are accepted for a period of one calendar month only. At the end of the one month period, the GTC order is automatically canceled. It is your responsibility to re-enter the order if so desired. In addition, should the price of a GTC (or any other) order be too far away from the then existing market price, FBRDirect reserves the right not to accept the order. It is your responsibility to keep track of all orders. You should check the Open Orders screen frequently for this purpose. Any failure by you to monitor your execution status does not excuse you from your obligation to make payment or delivery of securities by settlement date.

DUPLICATION OF ORDERS
When making changes to an existing unexecuted order, or attempting to make a trade that is subject to a prior unexecuted order, it is the customer’s responsibility to advise FBRDirect at that time, that a prior unexecuted open order is being changed or canceled. Your failure to advise FBRDirect that you are changing or canceling an existing order will result in the prior order remaining outstanding and subject to execution for your account and risk. FBRDirect will not be held responsible, financially or otherwise, for losses resulting from the failure of a customer to advise us that a prior unexecuted order is being canceled or changed.

ORDER CANCELLATION AND CHANGE REQUESTS, LATE AND CORRECTED REPORTS
When you place a request to cancel or change an existing order, the cancellation or change of stipulated terms is not guaranteed. Your order will only be canceled or changed if your request is received in the marketplace and matched up with your order before your order executes. Market orders are subject to immediate execution. During market hours, it is rarely possible to cancel your market order. For the best chance of ensuring that a market order is canceled, a cancellation request should be placed at least fifteen minutes prior to the opening of the market. Do not assume that any order has been executed or canceled until you have received a transaction confirmation from FBRDirect. Also, please be aware that FBRDirect, from time to time, receives late reports from exchanges and market makers reporting the status of transactions. Accordingly, you will be subject to late reports related to orders that were previously unreported to you or reported to you as being expired, canceled or executed. In addition, any reporting or posting errors, including errors in execution prices, will be corrected to reflect what actually occurred in the marketplace.

POLICIES RELATING TO EQUITY ORDER ROUTING
FBRDirect and National Financial Services LLC (NFS), a Fidelity Investments Company route equity orders taking into consideration, among other factors, the quality and speed of execution as well as the credits and cash payments receivable from the New York Stock Exchange, Inc. ("NYSE") and other market centers. Equity orders are generally eligible for possible price improvement. Specialists and Dealers accomplish this by exposing the order to competition, size guarantees, or by stopping the order temporarily at the current bid or offer and providing the Specialist or Dealer the opportunity to improve the price. The nature and source of any payments and/or credits received in connection with your specific transactions will be furnished upon written request.

ORDER ROUTING
While orders are typically routed to the marketplace within seconds, orders are subject to manual review and entry at FBRDirect's discretion. This review may cause delays in the processing of your orders. You will receive a price existing in the marketplace at the time the order is executed in the market. This price may be different from the price at which the security or option was trading when you enter your order into the FBRDirect system.

POLICIES RELATING TO JOINT ACCOUNTS
For accounts held jointly, each of the joint parties to the account shall have full authority on behalf of the joint account to act in all respects to the account, including purchase and sale (including short sales) of securities, bonds, and/or options, and to receive on behalf of the joint account money, securities and other property, and to receive on behalf of the joint account confirmations, statements, and communications of every kind with reference to the joint account. Whether you are joint tenants or tenants in common, your liability shall be joint and several. FBRDirect is specifically authorized to follow the instructions of any one of you in every respect regarding the joint account. It is the express intention of the joint parties to the account that ownership of the account be vested in them by the category selected on the account application:

Joint Tenants With Rights of Survivorship and not as tenants in common or as tenants by the entirety. In the event of the death of either or any of the undersigned, the entire interest in the Joint Account shall be vested in the survivor or survivors on the same terms and conditions as theretofore held, without in a manner releasing the undersigned or their estates from the liability provided for in this agreement.

Community Property. In the event of the death of either of the married parties undersigned, the entire interest in the Community Property Account shall be vested in the surviving spouse on the same terms and conditions as theretofore held, without in any manner releasing the undersigned or their estates from the liability provided for this agreement.

Tenants in Common. In the event of death of either or any of the undersigned, the interests in the tenant shall be equal unless otherwise specified immediately below.

RULES RELATING TO MARGIN ACCOUNTS
As a pre-condition to maintaining an FBRDirect brokerage account with National Financial Services LLC (NFS), a Fidelity Investments Company, all legally qualified accounts establish a margin account with National Financial Services LLC (NFS), a Fidelity Investments Company by signing the FBRDirect account application. While it always remains your choice whether to conduct your account on a pay-as-you-go basis or to utilize the credit available to a margin account, FBRDirect requires the signed margin agreement for our mutual convenience and protection. In addition, an initial deposit of $10,000 (which may consist of cash and/or marketable securities valued at $5 per share or greater) is required prior to the acceptance of an order for any purchases in a margin account. FBRDirect reserves the right to require a larger deposit should it be deemed appropriate. Securities selling under $5 per share and bonds which are high yield/high risk will not be accepted by FBRDirect as marginable securities in margin accounts. Should the price of a security in a margin account decline below $5 per share, the security may be moved to the customer’s cash account and additional funds and/or qualified securities will be required, if necessary, to meet margin maintenance requirements. At the discretion of FBRDirect, securities priced above $4 but below $5 per share in cash accounts may be used for maintenance purposes in securities margin accounts where the equity percentage has fallen below minimum house and/or regulatory requirements. Under most conditions, and pursuant to FBRDirect house policy, which may be changed from time to time without prior notice, 30% (or higher depending on the securities held) equity must be maintained in a margin account. When the equity percentage in a margin account falls below our minimum requirements, a maintenance call may be issued requiring the deposit of additional cash or marginable securities priced above $5 per share. A single security position in a margin account exceeding 30% of the total assets in the account is deemed to be concentrated. Under these conditions, FBRDirect may impose, at its discretion and without prior notice, higher equity requirements for a concentrated position. Most Limited Partnership interests and Depository Units are not eligible for deposit with the Depository Trust Company ("DTC"). As a general policy, interests ineligible for deposit with DTC will not be accepted by FBRDirect as collateral in margin accounts. Customers with margin accounts should be aware that their margin agreement grants to FBRDirect, at FBRDirect's discretion and without any advance notice to you, the right to liquidate sufficient securities for your account and risk in order to comply with FBRDirect's house and applicable regulatory margin requirements. Implicit in this authority granted to FBRDirect by your margin agreement, is the right of FBRDirect to demand that any margin maintenance call be met by the same or next day receipt of guaranteed funds in the form of a cashier’s or certified check drawn on a banking institution and/or qualified securities. You should be aware that in periods of rapidly declining securities prices, FBRDirect is more likely to exercise this provision of your margin agreement than in periods where the value of your securities remains relatively stable. It is therefore incumbent upon you to monitor the status of your margin account at all times to insure that sufficient cash and/or qualifying securities are on deposit with FBRDirect to forestall any liquidation. Additional copies of your signed margin agreement will be supplied to you upon written request to FBRDirect. FBRDirect does not allow margin accounts for non-residents of the United States. From time to time, and at FBRDirect's discretion, FBRDirect may impose margin requirements more stringent than those required by law or regulatory bodies. Such house requirements may be changed or modified by FBRDirect from time to time without prior notice. Customers of FBRDirect agree to comply with said house requirements in addition to all legal and regulatory requirements governing their accounts. Any waiver by FBRDirect or failure to promptly enforce such house requirements, as to your account or that of others, shall not limit or otherwise prevent FBRDirect from subsequently enforcing said requirements with regard to your account. Orders on securities deemed not suitable for margin, if accepted, will be placed in the cash account.

FBRDirect requires that all accounts maintain a minimum equity of $10,000.

FBRDirect may at its discretion, at any time, without prior notice, restrict the extension of credit in any account for any reason or suspend the extension of credit on specific securities for any reason.

Margin is a fully recourse, personal debt of the account holder. Any deficiency in the margin account, even if all the securities have been sold out of that account, remains your responsibility as the account holder.

POLICY REGARDING PRESUMPTION OF RECEIPT OF COMMUNICATIONS
Reports of the execution of orders, placement of open orders and statements of your account shall be conclusive if not objected to by you in writing within five (5) days, after transmittal to you by mail or otherwise. Communications mailed to you at the address specified on your application, including margin calls, shall be deemed to have been personally delivered to you, and you agree to waive all claims resulting from failure to receive such communications until FBRDirect has received notice in writing of a different address. FBRDirect cannot be held responsible for the accuracy of the price as reported if the order was in fact executed at another price; FBRDirect will report the correct information as soon as possible.

REQUESTING COMPANY DISCLOSURE
Rule 14b-1(c) of the Securities Exchange Act requires disclosure to requesting companies of the name, address and security position of customers who are beneficial owners of that company unless the owners object. This disclosure is intended to provide for improved communications between companies and their shareholders. Companies are prohibited from using disclosed information for any purpose other than direct shareholder communication. FBRDirect and National Financial Services LLC (NFS), a Fidelity Investments Company will release your name, address and security positions to requesting companies in which you hold securities unless you issue FBRDirect instructions to the contrary in writing.

POLICIES RELATING TO CUSTOMER’S RESPONSIBILITY REGARDING CERTAIN SECURITIES
Certain securities may grant the holder thereof valuable rights that may expire unless the holder takes action. These securities include, but are not limited to, warrants, options, stock purchase rights, convertible securities, bonds and securities subject to a tender or exchange offer. You are responsible for knowing the rights and terms of all securities in your Account. FBRDirect is not obligated to notify you of any upcoming expiration or redemption dates, or to take any other action on your behalf, without specific instructions from you, except as required by law and applicable rules of regulatory authorities. However, if any such security is about to expire worthless or be redeemed for significantly less than its fair market value, and we have not received instructions from you, FBRDirect may, at its discretion, sell the security and credit your Account with the proceeds. Similarly, you are responsible for knowing about reorganizations related to securities which you hold, including but not limited to stock splits and reverse splits. FBRDirect is not obligated to notify you of any such reorganizations. If, due to a reorganization, you sell more shares of a security than you own, or if you become uncovered on an options position, or if you become otherwise exposed to risk requiring FBRDirect to take market action in your Account, FBRDirect will not be responsible for any losses you incur. Overselling in a Cash or Margin Account is an impermissible short sale and may result in your Account being restricted.

FREE-RIDING
Free-Riding, the practice of selling securities to pay for the purchase of such securities violates Regulation T of the Federal Reserve Board and will result in your account being restricted and/or closed.

ONLINE SERVICES
You agree to use the FBRDirect online and telephone services (collectively, the "Service"), and any additional services offered through the Service in the future, only in accordance with these Policies and Procedures and Rules and any other Policies and Procedures with respect to the Service. You agree that you shall be the only authorized user of the Service under this Agreement. You shall be responsible for the confidentiality and use of your account number and password. You understand that you shall be solely responsible for all activities, including brokerage transactions, entered through the Service using your account number and password. You also understand that you will be fully and solely responsible for all activities, including brokerage transactions, which arise from you authorization to link your brokerage account(s) to any other FBRDirect brokerage account(s). You further understand and agree that, as a condition of using the Service to place orders and send/receive information, you shall immediately notify FBRDirect if: (a) an order has been placed through the Service and you have not received an order number; (b) an order has been placed through the Service and you have not received an accurate acknowledgment (whether through hard copy, electronic or verbal means) of the order or of its execution; (c) you have received acknowledgment (whether through hard copy, electronic or verbal means) of the existence of or an execution for an order which you did not place, or any similar conflict; or (d) you become aware of any unauthorized use of your account number and password.

If you fail to notify FBRDirect as soon as practicable when any of the above conditions occur, neither FBRDirect nor any of its officers, employees, agents, affiliates or subsidiaries can or will have any responsibility or liability to you or to any other person whose claim may arise through you for any claims with respect to the handling, mishandling or loss of any order.

You further agree that FBRDirect will not be liable for any consequential, incidental, special, or indirect damage (including lost profits, trading losses and damages) that result from inconvenience, delay or loss of the use of the Service even if FBRDirect has been advised of the possibility of such damages.

You agree that FBRDirect will not be liable for any losses resulting from a cause over which FBRDirect does not have direct control, including but not limited to the failure of, or delay caused by, electronic or mechanical equipment or communication lines, telephone or other interconnect problems (such as not being able to connect to, or delays caused by, your ISP), unauthorized access, theft, operator errors, acts of God, strikes or other labor problems.

FBRDirect may at its discretion, at any time, and without prior notice, restrict access to one or more communication options for any account, for any reason.

ALTERNATIVE ACCESS
FBRDirect may offer you various ways of accessing your Account, including online, touchtone, live representative, and interactive voice response. You agree that should you experience any problems in reaching FBRDirect through any particular method, you will attempt to use alternate methods to communicate with us.

ELECTRONIC COMMUNICATIONS
You agree that prospectuses and shareholder documents will be provided by via access to them on the FBRDirect Web site. You will be notified via Internet e-mail of new initial public offerings available to investors and shareholder documents, which have been updated or added to the FBRDirect Web site.

You agree to directly access the documents by hyperlink from the e-mail message itself. If the hyperlink function does not work for any reason, you agree to access the documents by going to the Internet address specified in the notification e-mail.

You agree that delivery of prospectuses to you may be made in electronic form by providing access to the FBRDirect Web site. Delivery of the prospectus by providing access on the FBRDirect Web site shall constitute good and effective delivery of the preliminary (Red Herring) and final prospectus whether or not you follow the instructions and actually access the prospectus via the FBRDirect Web site. You may withdraw this consent at any time, by written notice mailed to FBRDirect. Federal and state securities laws require delivery of the prospectus.

You agree to provide a current, correct and operational e-mail address. FBRDirect and its affiliates are not liable for undelivered electronic communications. That you may revoke your consent at any time, but revocation will immediately exclude you from participation in future FBRDirect initial public offerings. Investors will also be excluded from participation in future FBRDirect initial public offerings if FBRDirect becomes aware that the investor can no longer receive the documents via electronic delivery. You may inform FBRDirect of your decision to revoke consent by sending notice of your decision to revoke consent via first class U.S. mail to: FBRDirect, 1001 Nineteenth Street North
Arlington, VA 22209.

You agree that you will be able to print and download prospectuses and shareholder documents, which you may wish to do in case the Web site becomes temporarily unavailable to you for any reason. All required information will be accessible using the same software and hardware as that needed to access FBRDirect. That you acknowledge and agree that Internet e-mail is fallible, and you will access the FBRDirect Web site periodically for up-to-date information. If for any reason you do not receive an e-mail notification that is sent, you may miss time-sensitive information.

The consent to receive prospectuses and shareholder documents electronically applies to all documents, including but not limited to prospectuses, quarterly and annual filing with the Securities and Exchange Commission, annual shareholder reports, periodic account statements, transaction confirmations, and proxy solicitations.

Although investors consent to the electronic delivery of transaction confirmations, such documents may, at FBRDirect’s option, be sent in paper format, and will be provided on request.

That you may not limit the breadth of the consent to exclude certain documents. You may incur costs for online access and time in accessing documents and maintaining an e-mail account. You acknowledge and agree that information transmitted over the Internet, which may include personal information, may not be entirely secure, and that FBRDirect and its affiliates are not liable for misused information.

MARKET DATA
You understand that each participating national securities exchange or association asserts a proprietary interest in all of the market data it furnishes to the parties that disseminate the data. You also understand that neither any participating national securities exchange or association nor any supplier of market data guarantees the timeliness, sequence, accuracy, or completeness of market data or any other market information, or messages disseminated by any party. Neither FBRDirect nor any dissemination party shall be liable in any way, and you agree to indemnify and hold harmless FBRDirect and such disseminating party, for (a) any inaccuracy, error, or delay in, or omission of (i) any such data, information, or message or (ii) the transmission or delivery of any such data, information, or message; or (b) any loss or damage arising from or occasioned by (i) any such inaccuracy, error, delay, or omission, (ii) non-performance, or (iii) interruption of any such data, information, or message, due either to any negligent act or omission by FBRDirect or any dissemination party or to any "force majeure" (i.e., floods, extraordinary weather conditions, earthquake, or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications, power failure, or equipment or software malfunction) or any other cause beyond the reasonable control of FBRDirect or any dissemination party. You understand that the terms of this Agreement may be enforced directly against you by the national securities exchanges and associations providing market data. You shall use real-time quotes only for your individual use and shall not furnish such data to any other person or entity.

Price quotations listed on the site may be delayed or inaccurate and the price of a security contained on the site may differ from the current price for a variety of reasons including sudden market movements.

PERSONS NOT RESIDING IN THE U.S.
If you are not residing in the U.S. at the time of any controversy between yourself and FBRDirect subject to the arbitration provision of the Customer Agreement, you agree to those provisions and the following additional provisions:

(1) You agree that the rules of the organization administering the arbitration, namely the National Association of Securities Dealers, Inc. specifically provides for the designation of the place where the arbitration is to take place;

(2) You agree to the personal jurisdiction of the courts of the Commonwealth of Pennsylvania, U.S.A. to interpret and enforce these arbitration provisions described in the Agreement; and

(3) All arbitrations shall be held in the English language, unless otherwise agreed to by the parties.

CUSTOMER AGREEMENT
The terms and conditions of the Customer Agreement by and among you, FBRDirect, and National Financial Services LLC (NFS), a Fidelity Investments Company also govern your FBRDirect brokerage account with National Financial Services LLC (NFS), a Fidelity Investments Company. The Customer Agreement, your Account Application, and the Statement of Policies and Procedures and Rules must be read together.

PRIVACY AND SECURITY POLICY
FBRDirect employs security protections for electronic communications and restricts the use of personal and financial customer information received electronically. This is achieved by the use of user names, passwords, data encryption and the placement of such information on a secure Web site. Information transmitted over the Internet may not be entirely secure. FBRDirect, its affiliates and agents disclaim all liability for any misuse of the information conveyed via electronic communication. Please see the Privacy and Security Statement for more information.

DOW JONES POLICIES AND PROCEDURES
TERMS AND CONDITIONS OF USE OF DOW JONES INDEXES BY ACCESSING AND USING THE DATA RELATED TO DOW JONES INDEXES (INCLUDING, WITHOUT LIMITATION, THE INDEX VALUES, HEREAFTER COLLECTIVELY "DOW JONES INDEXES") ON THIS WEB SITE, YOU ARE AGREEING TO BE LEGALLY BOUND BY THESE TERMS AND CONDITIONS, INCLUDING ALL AMENDMENTS MADE AFTER MARCH 2003. IF ANY OF THESE TERMS AND CONDITIONS ARE UNACCEPTABLE TO YOU, YOU MAY NOT ACCESS OR USE DOW JONES INDEXES. GENERAL TERMS AND CONDITIONS OF USE

Dow Jones Indexes (including, without limitation, the Dow Jones Averages, Dow Jones Global Indexes, Dow Jones Titans Indexes, Dow Jones Islamic Market Indexes, Dow Jones Sustainability Indexes and Dow Jones-AIG Commodity Indexes) are proprietary to Dow Jones & Company, Inc. (Dow Jones) and/or its licensors. By accessing and using the Dow Jones Indexes, you are indicating that you are at least 18 years old, and you agree to be bound by all these Terms and Conditions of Use. You may print and keep a copy of these Terms and Conditions of Use, but Dow Jones may change any of these terms at any time. When the terms are changed, the changes will appear in this document. Your use of Dow Jones Indexes after any changes have been posted will constitute your agreement to the modified Terms and Conditions of Use. Therefore, you should read these Terms and Conditions of Use from time to time. If you do not agree to be bound by these Terms and Conditions of Use or any changes thereto, you should not use Dow Jones Indexes again. PROPRIETARY RIGHTS AND LIMITATIONS ON USE Dow Jones Indexes are protected by copyright and other intellectual property laws. Dow Jones Indexes may be used only for your personal, non-commercial purposes. You agree not to modify, copy, reproduce, retransmit, distribute, sell, publish, broadcast, create derivative works from or store the Dow Jones Indexes (or any portion thereof), without the express prior consent of Dow Jones. You may not use Dow Jones Indexes for any unlawful purpose. All trade names, trademarks, service marks associated with the Dow Jones Indexes (whether registered or unregistered) (the "Marks") are proprietary to Dow Jones and/or its licensors and are protected by applicable trademark laws. Nothing contained in this web site should be construed as granting any license or right to use any of the Marks displayed here without the express written permission of Dow Jones or the applicable licensors . Any unauthorized use of the Marks is strictly prohibited. Also, you may not use any of the Dow Jones Indexes or the Marks in connection with the issuance, trading, marketing or promotion of investment products (e.g., derivatives, structured products, investment funds, investment portfolios, etc. where the price, return and/or performance of the investment product is based on or related to the Indexes) without a separate written agreement with Dow Jones. Further, neither Dow Jones nor its licensors is giving investment advice, tax advice, legal advice, or other professional advice by providing the Dow Jones Indexes, and neither Dow Jones nor its licensors sponsor, recommend or endorse the purchase or sale of any security or investment. If you violate any of these terms and conditions, Dow Jones has the right to terminate your access to all or any portion of the Dow Jones Indexes immediately without notice. Your right to use the Dow Jones Indexes is subject to any limits established by Dow Jones in its sole discretion.

DISCLAIMER OF WARRANTIES AND LIABILITY DOW JONES INDEXES ARE PROVIDED TO YOU "AS IS". NEITHER DOW JONES NOR ANY OF ITS AFFILIATES, AGENTS OR LICENSORS WARRANTS THE ACCURACY, COMPLETENESS, CURRENTNESS, NONINFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF THE DOW JONES INDEXES. ALTHOUGH DOW JONES MAKES REASONABLE EFFORTS TO COMPLY WITH ITS GUIDELINES REGARDING THE SELECTION OF COMPONENTS IN THE DOW JONES ISLAMIC MARKET INDEXES, DOW JONES CANNOT GUARANTEE OR WARRANT THAT THOSE INDEXES OR THE DATA RELATED THERETO WILL COMPLY WITH SHARIAH LAW OR OTHER ISLAMIC PRINCIPLES AND DOW JONES EXPRESSLY DISCLAIMS ANY SUCH WARRANTY. NEITHER DOW JONES NOR ANY OF ITS AFFILIATES, AGENTS OR LICENSORS SHALL BE LIABLE TO YOU OR ANYONE ELSE FOR ANY LOSS OR INJURY RESULTING DIRECTLY FROM USE OF THE DOW JONES INDEXES CAUSED IN WHOLE OR PART BY DOW JONES' NEGLIGENCE OR CONTINGENCIES BEYOND ITS CONTROL IN PROCURING, COMPILING, INTERPRETING, REPORTING OR DELIVERING THE DOW JONES INDEXES. IN NO EVENT WILL DOW JONES OR ANY OF ITS AFFILIATES, AGENTS OR LICENSORS BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DECISION MADE OR ACTION TAKEN BY YOU IN RELIANCE ON THE DOW JONES INDEXES. NEITHER DOW JONES NOR ANY OF ITS AFFILIATES, AGENTS OR LICENSORS SHALL BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES (INCLUDING, WITHOUT LIMITATION, CONSEQUENTIAL, SPECIAL, INCIDENTAL, INDIRECT, OR SIMILAR DAMAGES) EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. ADDITIONAL TERMS

Dow Jones may discontinue or change the Dow Jones Indexes, or their availability to you, at any time without notice. If any provision in these Terms and Conditions of Use is invalid or unenforceable under applicable law, the remaining provisions will continue in full force and effect. These Terms and Conditions of Use, your rights and obligations, and all actions contemplated by this agreement shall be governed by the laws of the State of New York, as if these Terms are a contract wholly entered into and wholly performed within the State of New York. These Terms and Conditions of Use constitute the entire agreement between you and Dow Jones relating to the Dow Jones Indexes, and they supersede any and all other agreements, oral or in writing, with respect to the indexes. The failure of Dow Jones to insist upon strict compliance with any term or provision shall not be construed as a waiver with regard to any subsequent failure to comply with such term or provision. Certain market data is provided by Reuters for use in calculating the Dow Jones Indexes. Reuters shall not be liable for any errors or delays in content, or for any actions taken in reliance thereon.



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