This page contains the following disclaimers and disclosure statements, provided by Securities & Investment Planning Company in compliance with regulatory requirements and in the best interest of our clients:

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DISCLAIMERS
Payment For Order Flow

Without specific order routing instructions from its customers, Securities & Investment Planning Company (“SIP”) may direct orders to various market centers, including other broker-dealers whom it believes will provide the best execution of the order. SIP may receive payment from dealers for orders it directs to them. Compensation is in the form of a per shares cash payment. The source and nature of the payment received in connection with a particular transaction will be furnished upon written request.

Limit Orders
SIP will handle any customer limit orders, whether received from its own customer or from another broker-dealer, with all due care so as not to “trade ahead” of a limit order. SIP will execute the limit order prior to trading at prices equal, or superior, to that of the limit order.

Market Orders
SIP will make all reasonable efforts to obtain the best possible price available at the time the order is received. In the event that a customer market order is placed at the same time as an order of SIP, the customer order will be completed prior to the SIP order.

Order Routing Information
SIP will ensure that its customers have ready access to routing information concerning orders. Upon the customer's request, SIP is required to disclose to the customer the identity of the venue to which his/her orders were routed for execution in the six months prior to the request, as well as whether those orders were a directed or non-directed order and the time of any transaction which resulted from such orders. Please contact SIP's Compliance Department for further information or to direct such an inquiry.

Customer Identification Notice
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person or Entity to open an account, as well as each authorized person who may act on behalf of the Entity. At minimum, firms are required to collect information on owners and/or authorized principals such as name, date of birth, address and identification numbers. A Social Security number or Taxpayer ID number is required for all accounts and a valid passport or another form of government-issued photo ID is required for each authorized person or applicant prior to the opening of an account. If an applicant or authorized person is a non-resident alien, then a copy of his/her passport and indication of the country of residence is required as well. Please include a clear, legible copy of both the front and back of the identification being provided.

A corporation, partnership, trust or other legal entity may need to provide other information as well, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement. Rules of the U.S. Department of the Treasury, Securities and Exchange Commission, Financial Industry Regulatory Authority(“FINRA”), and the New York Stock exchange already require that the customer provide most of this information. These rules may also require that the customer provide additional information, such as employment information, investment experience, investment objectives, and risk tolerance. 

Privacy Statement
SIP collects nonpublic personal information about its customers from the following sources: information from the customer application or other forms; information about the customer's transactions with SIP, its affiliates and others; and information SIP may receive from a consumer reporting agency. SIP does not disclose any nonpublic personal information about its customers or former customers to anyone, except as permitted by law. SIP restricts access to the personal and account information of its customers to those employees and affiliates who need to know that information in order to provide products and services to the customer. SIP maintains physical, electronic, and procedural safeguards to protect the privacy of the nonpublic personal information of its customers.

Business Continuity Program Disclosure
Securities & Investment Planning Company has developed a comprehensive Business Continuity Program (“BCP”) designed to safeguard our clients' assets and confidential information and to protect the lives of our associated persons in the event of a significant business disruption. As the occurrence, duration and impact of such disruptions are unpredictable, our BCP is founded on flexibility and continuing operational and financial assessments, aimed at a rapid recovery and resumption of our operations. On an ongoing basis, we reassess risks and our ability to respond to a variety of significant local and national internal and external disruptions. The issues addressed in detail in our BCP include alternate means of communications with clients, associated persons and regulators; alternate physical locations for associated persons; data back up and recovery (hard copy and electronic); financial and operational assessments; mission critical systems, relationships with critical business constituents, banks and counter-parties, regulatory reporting; and assuring our clients prompt access to their funds and securities.

Our full BCP is available only to our clients. That BCP reflects the care and planning that we have devoted to preparing for significant business disruptions and keeping that planning up-to-date for the benefit of our clients and our personnel.

Our BCP reflects our ability to draw upon on the collective resources of our geographically disparate branch offices and Firm personnel. Therefore, should telecommunications at our Chatham, NJ headquarters be disrupted (e.g. due to a utility failure) or that physical location become inaccessible due to a catastrophe, we aim to continue Firm functions and client access. For example, in the event of a local disruption, associated persons in a designated branch office are available to our clients for functions such as order taking, order entry, access to funds and market making. That branch office is not dependent on the area electrical power transmission grid that serves our headquarters and is therefore, unlikely to be affected by a power outage affecting our headquarters.

Our books and records, including client account information are backed-up and stored at a secure offsite location each business day, both in hard copy and electronically on the Firm's server. If our headquarters becomes inaccessible, client data is recoverable from this offsite location and our BCP is designed to enable our Firm to serve our clients with minimal interruption.

An additional layer of business continuity planning is afforded by our clearing firm, Jefferies & Company, Inc. Jefferies backs up important records in its offsite location, including our Firm's client positions and other critical business information. In the event of a significant business disruption that prevents our customers from contacting our Firm at its headquarters or a designated back-up branch office, clients can contact our clearing firm for access to their funds and securities and for certain trading functions. Jefferies may be contacted at 212-284-2300 and its Business Continuity Disclosure may be found at http://www.jefferies.com/cositemgr.pl/html/OurFirm
/CorporateInfo/Policies/BCP/index.shtml.

This Business Continuity Planning Disclosure has been prepared to satisfy the disclosure requirements set forth by the Financial Industry Regulatory Authority in NASD Rule 3510(e). For more information about our Business Continuity Plan, please contact us at 973-701-8033 or email us at customerservice@siponline.com .

FINRA BrokerCheck
FINRA BrokerCheck, formally known as the FINRA's Public Disclosure Program, allows investors to learn about the professional background, business practices, and conduct of FINRA member firms or their brokers. BrokerCheck may be accessed at http://www.NASDBrokerCheck.com, or at 800-289-9999. A FINRA investor brochure is also available upon request.

Securities Investor Protection Corporation (SIPC)
The non-profit corporation that protects securities customers of its members up to $500,000 (including $100,000 for claims for cash). An explanatory brochure is available upon request or at www.sipc.org .  You may also obtain information about SIPC by contacting them by phone, email or regular mail at Securities Investor Protection Corporation 805 15th Street, N.W. Suite 800 Washington, D.C. 20005-2215 Tel: (202)371-8300 Fax: (202)371-6728 Email: asksipc@sipc.org

Duplicates
Due to rising costs and the constant demand for correspondence, requests for duplicate confirms, account statements and 1099's will be charged a $35.00 fee. 48 hours advance notice is required for any such requests. Two weeks advance notice is required for any such requests made during the period from January 1 – April 15.

Inaccuracies and/or Discrepancies
Any inaccuracy or discrepancy in a customer account should be reported both to SIP and to Jefferies, the clearing firm. The contact information for such a report is:

Securities & Investment Planning Company
Phone: 973-701-8033 Fax: 973-701-8353
Attn: Joan Ciotola
19 Center Street
Chatham , New Jersey 07928

and

Jefferies & Company, Inc.
Phone: 212-336-7240 Fax: 212-336-7260
Attn: Larry Lindenmeier
Harborside Financial Center
34 Exchange Place
Plaza III, 7th floor
Jersey City , New Jersey 07311

Any oral communication should be re-confirmed in writing.\

Complaints
Complaints may be directed to the attention of the Chief Compliance Officer at SIP Headquarters at 19 Center Street , Chatham , New Jersey 07928 . The main telephone number is 973-701-8033.

Quality Assurance and Compliance
All calls and electronic correspondence may be monitored or recorded for quality assurance and/or compliance purposes.

***

2341. FINRA Margin Disclosure Statement

Margin Disclosure Statement

Your brokerage firm is furnishing this document to you to provide some basic facts about purchasing securities on margin, and to alert you to the risks involved with trading securities in a margin account. Before trading stocks in a margin account, you should carefully review the margin agreement provided by your firm. Consult your firm regarding any questions or concerns you may have with your margin accounts.

When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firm's collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account.

It is important that you fully understand the risks involved in trading securities on margin. These risks include the following:

  • You can lose more funds than you deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities or assets in your account(s).
  • The firm can force the sale of securities or other assets in your account(s). If the equity in your account falls below the maintenance margin requirements, or the firm's higher "house" requirements, the firm can sell the securities or other assets in any of your account held at the firm to cover the margin deficiency. You also will be responsible for any short fall in the account after such a sale.
  • The firm can sell your securities or other assets without contacting you. Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.
  • You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests.
  • The firm can increase its "house" maintenance margin requirements at any time and is not required to provide you advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. Your failure to satisfy the call may cause the member to liquidate or sell securities in your account(s).
  • You are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension.

Adopted by SR-NASD-00-55 eff. June 4, 2001; amended by SR-NASD-2002-69 eff. July 1, 2002.
http://www.finra.org

 

2361. FINRA Day-Trading Risk Disclosure Statement

(a) Except as provided in paragraph (b), no member that is promoting a day trading strategy, directly or indirectly, shall open an account for or on behalf of a non institutional customer unless, prior to opening the account, the member has furnished to each customer, individually, in writing or electronically, the disclosure statement specified in this paragraph (a). In addition, any member that is promoting a day-trading strategy, directly or indirectly, must post such disclosure statement on the member's Web site in a clear and conspicuous manner.

Day-Trading Risk Disclosure Statement
You should consider the following points before engaging in a day-trading strategy. For purposes of this notice, a "day-trading strategy" means an overall trading strategy characterized by the regular transmission by a customer of intra-day orders to effect both purchase and sale transactions in the same security or securities.

Day trading can be extremely risky . Day trading generally is not appropriate for someone of limited resources and limited investment or trading experience and low risk tolerance. You should be prepared to lose all of the funds that you use for day trading. In particular, you should not fund day-trading activities with retirement savings, student loans, second mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required to meet your living expenses. Further, certain evidence indicates that an investment of less than $50,000 will significantly impair the ability of a day trader to make a profit. Of course, an investment of $50,000 or more will in no way guarantee success.

Be cautious of claims of large profits from day trading . You should be wary of advertisements or other statements that emphasize the potential for large profits in day trading. Day trading can also lead to large and immediate financial losses.

Day trading requires knowledge of a firm's operations. You should be familiar with a securities firm's business practices, including the operation of the firm's order execution systems and procedures. Under certain market conditions, you may find it difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a stock suddenly drops, or if trading is halted due to recent news events or unusual trading activity. The more volatile a stock is, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to system failures.

Day trading will generate substantial commissions, even if the per trade cost is low. Day trading involves aggressive trading, and generally you will pay commissions on each trade. The total daily commissions that you pay on your trades will add to your losses or significantly reduce your earnings. For instance, assuming that a trade costs $16 and an average of 29 transactions are conducted per day, an investor would need to generate an annual profit of $111,360 just to cover commission expenses.

Day trading on margin or short selling may result in losses beyond your initial investment . When you day trade with funds borrowed from a firm or someone else, you can lose more than the funds you originally placed at risk. A decline in the value of the securities that are purchased may require you to provide additional funds to the firm to avoid the forced sale of those securities or other securities in your account. Short selling as part of your day-trading strategy also may lead to extraordinary losses, because you may have to purchase a stock at a very high price in order to cover a short position.

Day Trading Requires Knowledge of securities markets. Day trading requires in-depth knowledge of the securities markets and trading techniques and strategies . In attempting to profit through day trading, you must compete with professional, licensed traders employed by securities firms. You should have appropriate experience before you engage in day trading.

Potential Registration Requirements. Persons providing investment advice for others or managing securities accounts for others may need to register as either an "Investment Advisor" under the Investment Advisors Act of 1940 or as a "Broker" or "Dealer" under the Securities Exchange Act of 1934. Such activities may also trigger state registration requirements.

(b) In lieu of providing the disclosure statement specified in paragraph (a), a member that is promoting a day-trading strategy may provide to the customer, individually, in writing or electronically, prior to opening the account, and post on its Web site, an alternative disclosure statement, provided that:

(1) The alternative disclosure statement shall be substantially similar to the disclosure statement specified in paragraph (a); and

•  The alternative disclosure statement shall be filed with the Association's Advertising Department

(Department) for review at least 10 days prior to use (or such shorter period as the Department may allow in particular circumstances) for approval and, if changes are recommended by the Association, shall be withheld from use until any changes specified by the Association have been made or, if expressly disapproved, until the alternative disclosure statement has been refiled for, and has received, Association approval. The member must provide with each filing the anticipated date of first use.

(c) For purposes of this rule, the term "day-trading strategy" shall have the meaning provided in Rule 2360(e).

(d) For purposes of this Rule, the term "non- institutional customer" means a customer that does not qualify as an "institutional account" under Rule 3110(c)(4).

[Adopted by SR-NASD-99-41 eff. Oct. 16, 2000; amended by SR-NASD-2002-69 eff. July 1, 2002.] Selected Notices to Members: 00-62, 02-35.
FINRA

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