SECURITIES INVESTOR PROTECTION CORPORATION

Georgeson Securities Corporation (“GSC”) is a member of the Securities Investor Protection Corporation (“SIPC”) and is required to advise its customers about how to obtain SIPC information. Information can be obtained from the following locations:

Website: www.sipc.org
Email: asksipc@sipc.org
Telephone: (202) 371-8300
Fax: (202) 371-1679
Address: Securities Investor Protection Corporation
1667 K St. N.W., Suite 1000
Washington, DC 20006-1620

CUSTOMER IDENTIFICATION PROGRAM

As a Financial Industry Regulatory Authority (“FINRA”) member, GSC is required to obtain certain customer identification information before opening new accounts. For more information about these customer identification requirements, here is a web link to FINRA’s Customer Identification Program Notice.

FINRA PUBLIC DISCLOSURE

FINRA Conduct Rule 2267 requires that GSC provide customers with certain information regarding its Public Disclosure Program.  The program permits the public to receive current regulatory information about FINRA member firms and their registered representatives. You can obtain more information by visiting: brokercheck.finra.org.

The FINRA Public Disclosure (BrokerCheck) Program Hotline Number and Address are:

FINRA BrokerCheck
P.O. Box 9495
Gaithersburg, MD 20898-9495

Telephone: (800) 289-9999
The FINRA Website address is: www.finra.org

Customers who wish to obtain a brochure that describes FINRA BrokerCheck should contact FINRA at the address or phone number listed above.

BUSINESS CONTINUITY PLAN (“BCP”) DISCLOSURE STATEMENT

GSC is responsible for creating and maintaining business continuity plans for all business lines. In the event of a business disruption, the firm has plans designed to allow us to continue operations of critical business functions, such as entering client orders, completing securities transactions and providing responses to customer inquiries. The business continuity plans have provisions designed to address the following:

  • Ensuring the safety of staff and visitors.
  • Relocating impacted businesses to designated recovery locations.
  • Using redundant processing capacity at other locations.
  • Designing technology and systems to support the data backup and recovery processes for critical business functions.
  • Using business and technology teams that are responsible for activating and managing the recovery process.
  • Activating a communication plan to ensure that GSC employees receive emergency notifications and instructions via a variety of sources, including telephone contact, toll-free phone numbers and websites.
  • Testing the Disaster Recovery Plan on a regular basis.
  • Minimizing risk from loss of services.
  • Maintaining customer service at an acceptable level.
  • Ensuring a smooth and effective transition from normal to alternative operations.

As part of the plan, GSC has identified the applications that are critical to all business units. These applications are to be implemented in separate production and recovery data centers.

If after a significant business disruption you cannot reach your regular GSC contact, you can call one of our alternate BCP offices at the following numbers: Jersey City, New Jersey (201) 680-6709 or Edison, New Jersey 866-785-6787.

If you cannot access us through either of those means, you should contact our clearing firm, Bank of America Securities, Inc. (“BofAS”), see contact information below.

Rastko Tomin
Director - Prime Financing  
1 Bryant Park, 5th Floor, New York, NY 10036 
T 646.743.0910 | F 212.548.8667
rastko.tomin@bofa.com

Although significant steps to develop and implement sound business recovery plans are in place, we cannot guarantee that systems will always be available or recoverable after a disaster or significant business disruption. However, we believe that our planning for such events is robust and consistent with many of the best practices established within the industry.

If you have questions about our BCP, please contact GSC Trading/Operations at tradingteam@gscorp.com

ORDER ROUTING INFORMATION

U.S. Securities and Exchange Commission (SEC) Rule 606 states that broker dealers that route customer orders in equity and option securities are required to make publicly available quarterly reports that, among other things identify the venues to which customer orders are routed for execution. BofAS publishes quarterly statistical information about its routing practices for non-directed orders in U.S. exchange-listed equity securities and options. GSC exclusively routes orders in Rule 606 reportable securities to BoAS for order routing. GSC does not select the execution venues to which BoAS routes 606 reportable securities for execution. As a result, BoAS is better positioned to prepare a quarterly report that reflects any execution venue specific maker-taker arrangements. GSC has examined the most recent quarterly report and does not have reason to believe it materially misrepresents the order routing practices. If you have questions about our order routing, please contact GSC Trading/Operations at tradingteam@gscorp.com

The link to receive these reports is: https://public.s3.com/rule606/bofas/

PAYMENT FOR ORDER FLOW

SEC Regulation NMS Rule 607 requires GSC to disclose its payment for order flow practices. In connection with this rule, GSC has no payment for order flow relationships with any broker dealers or third-party execution providers, including its clearing firm BofAS.

MARKET ON CLOSE (“MOC”)/ LIMIT ON CLOSE(“LOC”)

GSC’s Trading Desk follows the NYSE opening and closing auctions timelines. Timeline details can be found in the following link: NYSE opening and closing auctions

LIMIT ORDERS 

BofAS’ policy is to reject limit orders when the limit price is more than 30% BELOW the current market price, which represents the highest displayed bid price available for a security across the various exchanges or relevant trading platforms. For example, if the market price is $10, your sale order will be rejected if you set a limit price of $5, which is 50% below the current market price. Limit orders placed after hours, as well as existing Good-‘til-Cancelled orders, are subject to screening for the 30% threshold in pre-market each trading morning. Also, the maximum limit price you can set is dynamically capped at 600% ABOVE the current market price (the equivalent of seven times the current price). For example, if the current market price is $10 per share, the maximum limit order price you will be able to set is $70 per share. The limit order price cap is dynamic and changes with fluctuations in share prices. Thus, if the market price increases to $12, the maximum limit order price will increase to $84.

EXTENDED HOURS TRADING RISK

GSC does not execute extended hour trades (before 9:30AM and after 4:00PM) for its clients. 

INSTITUTIONAL ACCOUNTS

GSC considers your account to be an "institutional account," as defined under FINRA Rule 4512 (c)

SUITABILITY

GSC, based on FINRA Rule 2211, has a reasonable basis to believe that (i) the institutional customer is capable of evaluating investment risks independently, both in general and with regard to particular transactions and investment strategies involving a security or securities and (ii) the institutional customer will exercise independent judgment in evaluating the member's or associated person's recommendations. Please note that GSC does not provide any investment recommendation or investment related advise.

ANTI MONEY LAUNDERING

The USA Patriot Act (the “Act”) was established to detect, deter, and punish terrorist acts in the US and around the world.  The Act imposes anti-money laundering requirements on broker-dealers and other financial institutions.  Under the Act’s provisions, all broker-dealers are required to have comprehensive anti-money laundering programs with procedures and controls that include verification of the identification of new customers, reporting suspicious transactions, reporting certain currency/asset transfers, designation of a compliance officer, and conducting an independent audit of the program.  All customer transactions conducted by GSC are subject to compliance with the Act.  As part of GSC’s required program, it may request that you provide various identification documents or other information.  GSC will not be able to open an account or effect any transactions on your behalf until all required information and/or documentation has been provided.

You agree that, if required by applicable law, (i) you will adopt and implement anti-money laundering policies, procedures and controls that comply (and will continue to comply) in all respects with the requirements of applicable anti-money laundering law and other applicable law; (ii) you will at all times adhere to your anti-money laundering policies, procedures and controls; (iii) you will verify the identity of, and will conduct due diligence (and, where appropriate, enhanced due diligence) with regard to your customers in accordance with your anti-money laundering policies, procedures and controls and will provide GSC with that information upon request; and (iv) you will maintain records of procedures used to verify the identity of investors and update such information on a regular basis.

You acknowledge that you are not (i) a “foreign shell bank,” (ii) a resident of a non-cooperative Financial Action Task Force jurisdiction or an individual or organization operating in a jurisdiction or industry designated as being of primary money laundering concern by the U.S. Secretary of Treasury; (iii) an individual or organization which the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has listed as a “Specially Designated National and Blocked Person”; or (iv) a resident of any embargoed country as determined by OFAC.

EMAIL DELIVERY SECURITY

If you suspect your email account has been compromised, please contact GSC immediately at (866) 785-6787 so that you can instruct us to temporarily suspend any electronic delivery of sensitive account information as needed until you can resolve those issues with your internet service provider.

FINANCIAL STATEMENTS

Pursuant to Rule 17a-5 under the Securities Exchange Act of 1934, GSC is required to periodically provide certain financial information to each of its customers.  Copies of GSC’s most recent audited annual reports may be found below:

GSC will also make the audited annual reports available to its customer(s) upon written request.

PRIVACY NOTICE (SEC RULE S-P)

GSC maintains only institutional accounts and does not maintain any “customer” or “consumer” relationships as defined in SEC regulation S-P. In the event and at such time that GSC has “customer” or “consumer” relationships, as defined in SEC regulation S-P, GSC will adopt a Privacy Policy to be provided to customers at the time the account is opened and annually thereafter.

If GSC receives or is in the possession of personal information, GSC, as a wholly owned subsidiary of Georgeson LLC, will adhere to the privacy policy of Georgeson LLC as it relates to the handling of personal information.

Keeping client information secure is a top priority for GSC and its employees. GSC may collect and maintain certain personal information during the institutional account opening process.  GSC may share the personal information GSC collects with affiliated companies and with other service providers as reasonably necessary to process a transaction or to otherwise provide services.  All such parties will be obligated to maintain the confidentiality of such information. GSC will not disclose any personal information to anyone outside these parties or sell this information to any parties for unsolicited marketing purposes.
GSC does not share information with other companies for purposes of marketing solicitations.

Additional Information for California, Connecticut, Colorado, Virginia, and Utah Residents

In addition to the information provided above, if you are a current resident of California, Connecticut, Colorado, Virginia, or Utah you may have certain rights regarding your personal information. For our clients that meet the definition of a Business/Controller under the applicable state privacy law, GSC will assist those clients, to the extent possible, with the fulfillment of their obligations to respond to your requests. These may include, depending on the circumstance, the right to access the personal information that has been collected about you; delete your personal information; restrict our use of your personal information; and opt-out from the sale of your personal information (if applicable). GSC will not discriminate against applicable residents for exercising their rights under the US privacy laws. If you would like to discuss or exercise the rights you may have, feel free to contact us via email or mail as described in the section “How to Contact Us.”

HOW TO CONTACT US

If you have any questions about this statement, you may contact the US Privacy Team by email at USCSPrivacy@computershare.com or by mail to:

Computershare / Georgeson Securities Corporation
150 Royall Street
Canton, MA 02021
Attention: US Privacy Team