Disclosures




Business Continuity Disclosure Statement


Electronic Transaction Clearing, Inc. ("ETC") is committed to protecting the interests of clients at all times. ETC has developed a plan to provide for business continuity (Continuity Plan) in the event that business is disrupted. The Continuity Plan addresses all critical business processes, including providing clients with the ability to buy and/or sell and providing access to securities and funds.

The Continuity Plan addresses interruptions that are either localized or regional in scope regardless of the cause. The Continuity Plan is reviewed and tested annually and has been approved by senior management.

Should a disruption occur at our headquarters in Los Angeles, California, some operational functions may be temporarily disrupted while staff relocates to predetermined alternative sites.

ETC has Information Technology services that are housed and operate concurrently in dual, geographically disperse sites. Either site is capable of supporting all critical functions should one site be disabled. Any business disruption at ETC will not result in the loss of your account information, securities or money.

Your securities and funds are held at banks, custodians and other providers of services to the securities industry that each have their own successfully tested business continuity capabilities. These facilities are all located remotely from ETC's corporate data processing sites.

In the event that a disruption occurs that affects ETC, relevant information, including contact information, will be prominently displayed on the website.



Order Routing Policy


Rule 11Ac1‐6 under the Securities Exchange Act of 1934 requires all broker‐dealers that route customer orders in equity and option securities to make publicly available quarterly reports that disclose the venues to which it routes "non‐directed" orders in covered securities. ETC does not route “non‐directed” orders. All routing decisions are made by ETC’s clients.


ETC Payment for Orderflow


The Securities and Exchange Commission (“SEC”) requires all registered broker-dealers to disclose their policies regarding receipt of “payment for order flow.” The Commission defines “payment for order flow” as “any monetary payments, services, property, or other benefits that result in remuneration, compensation, or consideration to a broker or dealer from any broker or dealer, national securities exchange, registered securities association, or exchange member in return for the routing of customer orders by such broker or dealer to any broker or dealer, national securities exchange, registered securities association, or exchange member for execution, including but not limited to research, clearance, custody, products or services, reciprocal agreements for the provision of order flow adjustment of a broker or dealer’s unfavorable trading errors, effort to participate as underwriter in public offerings, stock loans or shared interest accrued thereon, discounts, rebates, or any other reductions of or credits against any fee to, or expense or other financial obligation of, the broker or dealer routing a customer order that exceeds that fee, expense or other financial obligation.”

ETC generally does not negotiate payment for order flow. ETC’s clients self direct their orders, and are responsible for all of their own routing and order flow decisions. However, ETC, acting as agent, transacts business on varying market venues, and with varying market participants, and as such is subject to the standard schedule of transaction fees found therein, which may include certain rebates and or other cost savings. In addition, ETC may negotiate preferable rates for its clients at certain venues and or with certain participants, which also may include the payment of rebates, and or the provision of cost savings for certain order types, and or under certain conditions. In the course of transacting business on behalf of its clients, though not responsible for routing its client’s orders, ETC may be the recipient of certain rebates and or savings. As such, ETC may, in some cases, receive benefits that could be construed as falling within the above definition of “payment for order flow.”


Privacy Policy

   
In order to maintain and service your accounts, ETC will gather and store information about you. This information, collected via the new account application and other account documentation, is critical to open and administer your account. In addition to this collected information, transactions facilitated by you through ETC will be kept for reporting purposes and pursuant to ETC's regulatory requirements. To provide superior service to clients it is necessary for ETC to share information with third parties it is currently involved with in a contractual relationship (such as your referring financial institution); except in states where this type of sharing is not permitted by law. This sharing of personal information is carried out on a strictly professional basis and is incidental to servicing your account. ETC has received assurances from these third parties that they will not share your personal information. You understand that through the normal course of servicing your account, certain agents and employees may have access to your confidential account information. This may include operations and support personnel, as well as your investment professional. You understand that access to this information is limited and held in the strictest confidence. You understand that information about former customers who do not currently maintain an account relationship with ETC is not shared with any outside party. You understand that due to the partnerships that ETC has with financial institutions to offer investment services, sharing of information with these financial institutions is critical to servicing your account. Allowing this sharing process to continue uninterrupted will allow you to take full advantage of the value offered by the relationship between your financial institution and ETC. ETC does offer you the option to limit the sharing of information between ETC and your referring financial institution. If you would like to request that your information not be shared with your referring financial institution or if you would like more information about ETC's Privacy Policy, your request should be sent to ETC in writing to: Electronic Transaction Clearing, Inc., Attn: Compliance, 660 South Figueroa Street, Suite 1450, Los Angeles, California 90017; by email to compliance@etc-clearinq.com; or, telephoning ETC at (213) 402-1570.

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