Disclosures

Updated: July 16, 2019

  1. Business Continuity Plan Disclosure
  2. Capital Statement Disclosure
  3. Order Routing Disclosure
  4. Anti-Money Laundering Customer Information
  5. Privacy Policy Disclosure

Business Continuity Plan Disclosure - Sutter Securities, Inc.

Sutter Securities, Inc. (“Sutter”) is committed to providing uninterrupted service and support to our clients and customers in the event of an emergency or significant disruption of normal business operations.

Sutter has a Tri-party clearing relationship with Lantern Investments Inc. and Pershing LLC on a fully disclosed basis.

Sutter’s business continuity plan is designed to protect client assets. However, it is impossible to anticipate every possible scenario that may result in an emergency or business interruption. Therefore, our plan is subject to change without notice. Any changes will be posted on our website as soon as possible.

The statements contained in this disclosure statement are for informational purposes only. Nothing in this statement constitutes a change in the terms and conditions of any customer agreement or other agreement.

Capital Statement Disclosure

Sutter Securities, Inc.’s (“Sutter”) principals have contributed significant capital to the firm. In addition, Sutter has access to additional capital, if required. A Tri-party clearing relationship has been established with Lantern Investments Inc. and Pershing, LLC which allows Sutter to clear all of its trades on a fully disclosed basis.

Order Routing Disclosure

Pursuant to SEC Rule 11Ac1-6 we are providing this information to the public.

Under Rule 11Ac1-6, broker-dealers that route customer orders in equity and option securities will be required to make publicly available quarterly reports that, among other things, identify the venues to which customer orders are routed for execution. In addition, broker-dealers are required to disclose to customers, on request, the venues to which their individual orders were routed. By making visible the execution quality of the securities markets, the rules are intended to spur more vigorous competition among market participants to provide the best possible prices for investor orders.

For more information on SEC Rule 11Ac1-6, please visit the SEC’s web page at www.sec.gov, or the FINRA’s web page at www.finra.org.

Anti-Money Laundering Customer Information

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT:

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 who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. All major financial receipts and transfers may be subject to review.

Privacy Policy Disclosure

Privacy Statement For Individuals

As a Sutter Securities, Inc. (“Sutter”) client, your privacy is important to us. Reflecting the Firm’s commitment to protecting the privacy of your personal information, we have implemented privacy policies consistent with the rules mandated by federal guidelines for financial institutions. We have also adopted policies and procedures designed to help ensure the security and confidentiality of our customers’ records and information.

The Collection Of Personal Information

In order to help us provide the best level of service, better meet your financial needs, and provide the financial services that Sutter offers, we may collect information from the following sources:

  • Applications and other forms we have filled out (including information such as your name, address, social security number and income);
  • Your transactions with us, our affiliates, or others (including information such as account balances and transaction history);
  • Credit reporting agencies (who provide us with your credit history and information to protect both you and Sutter Securities against fraud).

Disclosure Of Personal Information To Nonaffiliated Third Parties For Business Purposes

We may disclose the information described above to companies that are not affiliated with Sutter for business purposes in the following circumstances:

  • Companies that perform administrative services on our behalf (such as vendors that provide data processing, transaction processing and printing services);
  • Our clearing broker.

Disclosure Of Personal Information In Other Instances

Sutter shares information with third parties not affiliated with the Firm, such as mortgage bankers, securities broker-dealers (other than our clearing broker-dealer) and insurance agents. Please feel free to contact our Compliance Department at 415-352-6340 if you have any additional questions.

In addition, we may also disclose the information described above to nonaffiliated third parties as permitted by law, for example, to comply with a subpoena, respond to a regulatory authority or to protect against fraud.

Information Confidentiality And Security

At Sutter, we restrict access to client information to those employees who need to know such information in order to perform their job responsibilities. Employees who have access to client information must adhere to our strict security and confidentiality policies.

Former Customers

Information pertaining to former clients will be treated as described in this policy.

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