Anti-Money Laundering Policies and Customer Identification Program
To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions to obtain, verify and record information that identifies each individual or institution that opens an account or establishes a customer or counterparty relationship with the firm. The firm deals solely with institutional customers, and extends the AML disclosure to all counterparties of the firm.
What this means: If you or your company enter into a customer relationship with the firm, the Firm will require names, address, date of birth (if applicable), and other identification information which may be appropriate given the nature of you or your company. This information will be used to verify your identity and the identity of your corporate entity. As appropriate, the Firm may, in its discretion, ask for additional documentation or information. The firm also has standards when opening an account for an institutional entity and shall require information and documentation such as but not limited to:
- Requesting certain information from you, such as the legal name of financial institution conducting trades and tax identification number, location and designation of persons using the services of the firm or those eligible to sign a contractual commitment, as well as any persons with trading authority (if applicable).
- Taking steps to check the information provided – to verify that institutions are who they say they are.
- Consulting applicable governmental agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if someone on any such list is attempting to open or maintain an account.
- Conducting in certain instances, additional due diligence when accounts are opened for foreign persons or institutions, and other certain clients.
The US Department of the Treasury, Securities and Exchange Commission, FINRA and New York Stock Exchange rules already required you to provide most of this information.
If you (as an institution) enter into a customer relationship with the Firm and are subject to the definition of customer as applied to AML rules, the Firm will ask for corporate information that identifies the name of the entity, its location, offices, types of firm, regulatory filings and some other particular information. The Firm will then do a non-documentary verification to identify the existence of the entity.
What happens if the information is not provided? The Firm may not be able to establish or maintain a business relationship with you. If the Firm has already established a relationship, it may have to terminate it. If you establish a relationship and refuse to provide this information, we may be required to report this action to appropriate governmental authorities.
Contact Information for Customer Complaints and Inquiries
Inquiries regarding trading inaccuracies or customer complaints should be forwarded to the Firm’s General Securities Principal, via phone at (212) 632-3600 or via email at firstname.lastname@example.org
Waller Capital Securities LLC
1 Rockefeller Plaza, 23rd Floor
New York, NY 10020
Telephone: (212) 632-3600
The services provided by the Firm are intended solely for the institutional investor. No actions of the Firm should be deemed to be a solicitation for the purchase or sale of any security. The Firm’s institutional clientele make independent analyses and determinations of the suitability of any investments decision the institutional investor may make. This product is not suitable for retail or individual investors and as such, non-institutional investors should not use the product herein as a determination of appropriate investment vehicles for their risk profile.
Inquiries regarding this disclosure should be directed to the firm’s General Securities Principal, at (212) 632-3600 or via email at email@example.com or via US mail to: Waller Capital Securities – Compliance Department, 1 Rockefeller Plaza, 23rd Floor, New York, NY 10020.
FINRA Rule 2266
FINRA Rule 2266 requires Waller to disclose SIPC contact information. Contact Information regarding SIPC, including a SIPC brochure, may be obtained by contacting SIPC via its website at www.sipc.org or by telephone (201) 371-8300.
Summary and Disclosures of BCP Planning
Waller Capital Securities LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (212) 632-3600 you should or go to our parent’s website at www.wallercapital.com. We will post contact notices there if necessary.
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our Firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Pershing LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions as quickly as possible.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our Firm, a single building housing our Firm, the business district where our Firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our Firm or a building housing our Firm, we will transfer our operations to a local site when needed and expect to recover and resume business as quickly as possible. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business as quickly as possible. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you via email and phone calls. If the significant business disruption is so severe that it prevents us from remaining in business, we will ensure the settlement of our existing trades.
For more information – If you have questions about our business continuity planning, you can contact us at (212 632 3600 or via email at firstname.lastname@example.org.
Pursuant to Regulation S-P, the Firm provides the following disclosure in relation to its use and protection of customer information. Our client’s personal information and corporate information remains secure with the Firm. We do not share client information with third parties, other than to process our business transactions and service client relationships and, in limited situations, where are required by law to do so.
If you wish to stop receiving information concerning our services or products, please contact us by email at email@example.com to notify us of your wishes.