Clarendon Securities
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Anti-Money Laundering

Under new rules required by the USA PATRIOT Act, our anti-money laundering program must designate a special compliance officer, set up employee training, conduct independent audits, and establish policies and procedures to detect and report suspicious transactions and ensure complieance wi the new laws.

As part of our required program, we may ask you to provide various identification documents or other information. Until you provide the information or documents we need, we may not be able to open an account or effect any transactions for you.

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Business Continuity Planning

Clarendon Securities 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 703-528-7994 or 800-368-7681 you should try an alternate number 800-431-0030 or our website at www.clarendonsecurities.com. If you cannot access us through either of those means, you should contact our clearing firm, National Financial Services LLC (NFS) on their Customer Service Line at 617-563-5977. NFS can give you instructions about how to enter orders and have access to your funds and securities.

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 back up 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, NFS, 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, our clearing firm has advised us that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments with minimal interruption. Your orders and requests for funds and securities could be delayed during this period.

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 within one hour. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area; we will transfer operations to NFS. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.ClarendonSecurities.com. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at 800-368-7681 or service@clarendonsecurities.com.

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New York Stock Exchange, Inc. Rule 382 Disclosure

Clarendon Securities has an agreement with National Financial Services, LLC, a Fidelity Investments Company whereby National Financial Services provides certain clearing services for us. New York Stock Exchange Rule 382 requires you to be informed about the allocation of responsibilities as set forth in the clearing agreement.

We will be responsible for the following areas:

  • Opening, approving and monitoring your account, obtaining and verifying you new account information and obtaining personal information from you including your investment objectives.
  • Supplying all account documentation required by National Financial Services.
  • Reviewing your account and all orders in it.
  • Accepting your orders and transmitting them to National Financial Services for execution.
  • The conduct of your account and ensuring that all the transactions conducted therein are in compliance with all applicable laws and rules.
  • Responding to any inquiries you may make concerning your account and if any inquiry concerns National Financial Services, we will be responsible for promptly notifying National Financial Services about each inquiry.

Any questions you may have concerning the conduct of your account should be addressed directly to us.

National Financial Services will be responsible for the following areas:

  • Maintaining books and records, in accordance with securities rules and regulations, which includes stock records, account documentation, and compiling and filing regulatory reports.
  • Receiving and delivering securities.
  • Receipt of dividend and interest payments for your account.
  • Any extensions of credit to you which includes complying with Regulation T of the Federal Reserve Board, determining maintenance margin, paying and charging interest and rehypothecation or loan of any of your margin securities.
  • Safeguarding funds and securities. You have Securities Investor Protection Corporation (SIPC) coverage for your funds and securities through National Financial Services when your funds and securities are in their possession for up to $500,000 ($100,000 in cash). Additional insurance is carried on accounts up to $25 million. Ask for details.
  • Preparing and transmitting statements to you.
  • Preparing and transmitting confirmations to you.
  • Transmitting proxy materials, and information concerning tender and exchange offers and any other form of corporate reorganization to you.

Accounts carried with National Financial Services, LLC, a Fidelity Investments Company.
Members NYSE/NASD/SIPC

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Privacy Policy

At Clarendon Securities, protecting the privacy and confidentiality of your personal information is important to our employees and us. We value your business and the trust you put in Clarendon Securities. We would like to assure you that, as explained more fully below, we will not make your personal information available for marketing purposes to anyone outside our organization.

In order to offer you the financial products and services you seek to obtain, we collect, maintain and use information about you on a routine basis. To help you better understand how your personal information is protected, we are providing you with the following statement describing our practices and policies with respect to the privacy of customers information. At Clarendon Securities:

We do not disclose any nonpublic personal information about you to anyone except as permitted by law. We may, for example, disclose nonpublic personal information about you to others for purposes of servicing your account with us, processing transactions that you request or authorize, or running credit or other verification checks.

W may collect information volunteered by you during the application process, gathered from your transactions and experiences with us and obtained from other authorized sources, such as credit bureaus. All information gathered and stored by Clarendon Securities is used for specific business purposes, such as administering your account complying with state/federal regulations, protecting against fraud and developing a better understanding of your financial need to provide you with improved products and services.

We restrict the access to your personal and account information to employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Internet Security

When you interact with a Clarendon Securities web site, we strive to make that experience easy, meaningful, and secure. We accomplish this in the following ways.

Cookies and Personal Identification. Standing alone, cookies, GIFs and other Web tools, as well as data derived from them, do not identify you personally. They merely recognize your browser. Unless you choose to identify yourself to FundCash through the Apply Online process, you remain anonymous to us. Cookies come in two flavors: persistent and session-based.

Persistent Cookies. Only persistent cookies remain on your computer after you've closed your browser or turned off your computer. They include such information as a unique identifier for your browser that only FundCash can read and use, and the fact that you are a customer or prior Web site visitor (whatever the case may be). We are especially careful about the security and confidentiality of the information we send through persistent cookies.

Session-based Cookies. Session cookies exist only during an online session with FundCash. They disappear from your computer when you close your browser software or turn off your computer. Session cookies allow you to conduct transactions or request your own personal or account information on our Web site. They contain encrypted or encoded information about your account(s), and/or identifying information that you have previously provided to us. This information allows Clarendon Securities to process your online transactions and requests. Examples include a request to see your account balance or to place a trade order on your behalf. Without the session cookie information, we would not be able to complete your Web transactions securely. Session cookies help us make sure you are who you say you are after you've logged in.

Secure Server through Verisign. Web security and keeping customer information secure is important to FundCash. All customer account transactions are done through the Presidential Bank secure web server (https://secure.presidential.com). On the bottom of each page of the FundCash web site, we have placed the Versign secure site logo that links to Verisign telling a visitor that our site is on a secure server.

Secure browsers. In order to better protect your personal information, Presidential Bank has adopted the policy of our customers using browsers capable of 128-bit encryption. This insures that the process of sending us your personal information over the World Wide Web is safe. The information is encrypted by your web browser using a "key" that will enable it to be legally decrypted only by us. Using a 128-bit cipher makes it exponentially more difficult than the previously accepted standard of 40-bit encryption.

In order to check the level of encryption your current browser is using, on the browser window choose the "Help" menu. From the Help menu choose "About Internet Explorer" or "About Netscape", depending on your browser type. In the "About" page it should say "Cipher Strength: 128-bit" for Microsoft's Internet Explorer, or Netscape users will see "This version supports high-grade (128-bit) security." If you are using any browser with a lower strength cipher than 128-bit encryption, you will NOT be able to view the online application for FundCash. You need to upgrade your browser version.

To upgrade your browser:

Microsoft Internet Explorer users got to:
http://www.microsoft.com/downloads/search.asp?
Select the product "Internet Explorer 6" (or the latest version
available) and your operating system and follow the directions to
download and install this browser.

For Netscape Navigator users go to:
http://channels.netscape.com/ns/browsers/default.jsp
Press the button "Free Download" and follow the instructions to download
and install this browser.

Make sure you specify if asked, to require a 128-bit encryption browser.

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SEC Rule 605 Trade Execution

In November 2000, the Securities and Exchange Commission (SEC) adopted, SEC Rule 605 and SEC Rule 606, concerning order execution and routing practices of the securities industry. The combination of these two rules is designed to increase the transparency of the securities markets for investors by requiring the public disclosure of order execution data by market centers and order routing practices of broker dealers who route customer orders to various market centers for execution.

SEC Rule 605 requires market centers that execute investor orders to make publicly available monthly reports of standardized statistical measures of execution quality. In order to facilitate comparisons across market centers, the SEC has adopted standardized measures of execution quality such as speed of execution, effective spread, rate of price improvement or disimprovement, and fill rates. Clarendon Securities does not make markets in equity securities or trade against our customers' orders, so we are not required to publish the monthly market center reports. However, we are providing a web site link to access the trade execution quality reports for NFS, our clearing firm, which links to reports on Fidelity’s trading activity.

SEC Rule 606 Order Routing

SEC Rule 606 is applicable to broker dealers such as Clarendon Securities who route customer equity and option orders to various venues for execution. This rule requires such firms to make publicly available quarterly reports that identify the market centers to which a significant percentage of non-directed customer orders have been routed for execution, the percentages of total non-directed orders that were market orders, limit orders, or other orders, the identity of the venues to which a significant percentage of total non-directed orders were routed for execution and the percentage of total non-directed orders routed to the venue, and the percentages of total non-directed market orders, non-directed limit orders, and non-directed other orders that were routed to the venue. In addition, this rule requires the broker dealer to disclose the nature of its relationship with each market center to which it routes orders, including payment for order flow and any profit sharing relationship. Also, customers can request details, from their investment representative, on the identity of the venue to which the customer's orders were routed for execution in the six months prior to the request, whether the orders were directed, at the customer's request, to a specific venue for execution and the time of the executions, if any, that resulted from those orders. Customers also may request up to six months of this information in hard copy through a representative on all orders for a specific time period and/or on individual securities.

For more information about order disclosure and this rule, visit The Securities Industry Association. www.sia.com.

Clarendon Securities is pleased to make publicly available the following report that describes our order routing practices in compliance with SEC Rule 606. In accordance with the requirements of SEC Rule 606, the report is divided into four separate sections - equity securities listed on the NYSE, equity securities qualified for inclusion in Nasdaq, equity securities listed on the AMEX, and one for Options. The order routing information for NFS, our clearing firm, can be accessed at the NFS web site.

DISCLAIMER

All information is provided "as is" without warranty of any kind. Clarendon Securities, and its affiliates, specifically disclaims all warranties express or implied with respect to the data, including specifically, but not exclusively, warranties as to accuracy, timeliness, and completeness of the reports and any warranties of merchantability, fitness for a particular purpose, and non-infringement. Clarendon Securities shall not have any liability for any indirect, consequential, special or direct damages for any action or inaction which may be taken as the result of the data, whether the claim be based in contract, tort, or otherwise.

In addition, Clarendon Securities in providing the information makes no endorsement of any particular security or market participant.

1 A "market center" is defined by SEC Rule 605 to include any exchange market maker, OTC market maker, alternative trading system, national securities exchange, or national securities association. However, market center does not include any of the option exchanges.

2 A "non-directed order" is defined by SEC Rule 606 to include any order where the customer has not specifically instructed the broker dealer to route the order to a particular venue for execution.

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Discount Brokerage Services Insured Money Market Account
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Clarendon® Securities, Inc., a division of GIT Investment Services, Inc.
Member of Financial Industry Regulatory Authority (FINRA) and
Securities Investor Protection Corporation (SIPC).
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