Clearing and Execution Services
Trade-PMR, Inc. has entered into an agreement withWells Fargo Clearing Services, LLC to execute and clear securities transactions for all accounts. Wells Fargo Clearing Services will carry and maintain these accounts (as defined by SEC Securities Investors Protection Act) under the terms of the fully disclosed clearing agreement, except as may otherwise be provided in the included Client Account Agreement.
Operating under the exception of SEC Rule 15c3-3(k)(2)(ii), TradePMR does not hold or take possession of client funds or securities. To comply with this provision, funding of all accounts and payment of transactions must be made payable toWells Fargo Clearing Services, LLC and mailed to PO BOX 358230, GAINESVILLE, FL 32635.
INVESTMENT OBJECTIVES/RISK TOLERANCE DEFINITIONS
The Investment Objectives and Risk Tolerances listed on the New Account Application (copy enclosed) are defined below. Your selections on the application along with other factors directly reflect the suitability of securities in your account and can create restrictions should the activity or holdings in the account not match your Investment Objectives and Risk Tolerances. If the Investment Objectives and/or Risk Tolerance on the application are incorrect or have changed, please send your changes in writing.
Income: Income investors seek a maximum amount of income given their risk tolerance, and are willing to forgo capital appreciation and growth of income.
Growth: Growth investors do not seek account income and their primary objective is capital appreciation.
Growth & Income: Growth and income investors seek current income, but also seek income and capital growth over time.
Trading & Speculation: These investors seek out a maximum return through a broad range of investment strategies which generally involve a high level of risk, including the potential for significant loss of principal.
RISK TOLERANCE LEVELS
Conservative Income: Conservative Income investors seek the maximum amount of income consistent with a modest degree of risk. They are willing to accept a lower level of income in exchange for lower risk. Equities and high yield bonds will typically not be a large percentage of the account.
Moderate Income: Moderate Income investors seek to balance potential risk with increased income potential. Equities and high yield bonds will typically be some percentage of the account.
Long-Term Income: Long – Term Income investors seek a significant level of income, and, due to their long term time horizon or other factors, they employ higher risk, more aggressive strategies that may offer higher potential income. Equities and high yield bonds may be a significant percentage of the account.
Conservative Growth & Income: Conservative Growth and Income investors, seek the maximum growth and income consistent with a relatively modest degree of risk. They are willing to accept lower potential returns in exchange for lower risk. Equities will typically be some percentage of the account, and will typically pay dividends.
Moderate Growth & Income: Moderate Growth and Income investors seek to balance potential risk with higher potential growth and income. Equities are typically a significant portion of the account, and will typically pay dividends.
Long-Term Growth & Income: Long – Term Growth and Income investors seek a significant level of growth and income, and their long term time horizon and/or other factors allow them to pursue higher risk, more aggressive strategies that may offer higher potential returns. Equities are typically the primary asset in the account, and will typically pay dividends.
Conservative Growth: Conservative Growth investors seek maximum growth consistent with a relatively modest degree of risk. They are willing to accept lower potential returns in exchange for lower risk. Equities will typically be a significant portion of the account.
Moderate Growth: Moderate Growth investors, seek to balance potential risk with their goal of higher potential growth. Equities are typically the primary asset in the account.
Long-Term Growth: Long Term Growth investors seek a significant level of growth, and due to their long term time horizon or other factors, they employ higher risk, more aggressive strategies that may offer higher potential returns. Equities may be as much as 100% of the account.
TradePMR is a member of both the SIPC (Securities Investors Protection Corporation) and FINRA (Financial Industry Regulatory Authority).
To contact the SIPC, visit their website at www.sipc.org or call 202-371-8300. To receive a brochure on the SIPC, please submit a written request to TradePMR, Attn: Compliance Department, PO Box 358230, Gainesville, FL 32635.
FINRA has a public disclosure program known as BrokerCheck® that allows clients to obtain background information on investment professionals and brokerage firms at www.finra.org or via the BrokerCheck® hotline at (800) 289-9999 Monday through Friday 8 a.m. – 8 p.m., Eastern Standard Time.
Complaints should be directed to the Compliance Department at PO Box 358230, Gainesville, FL 32635, or via telephone at 888-723-3767, ext. 6.
In November 1999, Congress passed major changes to modernize the laws that govern the financial services industry, including those designed to safeguard individual privacy. At TradePMR, protecting clients’ privacy is paramount. We recognize that an individual’s financial matters are extremely private and sensitive in nature. These laws and regulations, combined with our long-standing firm policies, enable us to protect your privacy and, at the same time, provide you with a broad range of accounts and high quality services.
We collect only the information that is required to provide you with the highest quality professional services or as required by law and regulation. This nonpublic personal information about you is collected from the following sources: information we receive from you on applications or other forms; information about your transactions with us, our affiliates, or others; and information we receive from consumer reporting agencies.
Employee access to client information is restricted to those who have a legitimate need to know in order to provide you with our professional services or to comply with laws and regulations. We maintain both physical and electronic safeguards in accordance with federal law and regulatory standards. Any employee who has access to individual information receives training and is required to follow company procedures designed specifically to keep your information confidential. Please notify us if our records contain incomplete or inaccurate information about you. We will promptly investigate your concerns and make any necessary corrections.
Protecting your privacy is an on-going process. As technology continues to advance, TradePMR will continue to evaluate its security standards and procedures in order to protect your information with the best available means. Nothing is more important to us than the client’s trust and confidence.
All broker-dealers are required by the Securities and Exchange Commission to make annual disclosure to clients concerning order routing practices and payment for order flow received from market centers and regional exchanges to which the broker-dealer routes orders for execution. We are providing you this information to assist you in understanding the process TradePMR employs.
TradePMR receives payment for routing certain orders in equity securities to specialized market maker firms for execution. Orders for securities entered “at the market” or “at quote limit” prices may be eligible for such payments. Other types of orders generally are not eligible for payments.
TradePMR and its affiliates believe that our order routing policies may provide significant benefits to clients. Practices engaged by specialized market maker firms and alternative market centers are designed to enhance quality and to provide opportunities for price improvement.
Upon written request, TradePMR will provide specific information regarding a particular transaction, including whether or not payment for order flow was received, the source of such payment, and the amount of such payment.
In compliance with the USA Patriot Act, TradePMR will verify information given on accounts using third party credit agencies in compliance with all government and industry regulations. Failure to provide adequate and correct information on any account will result in reporting to the proper government enforcement agency.
TradePMR clears all of its business with its clearing firm,Wells Fargo Clearing Services, LLC. All orders are routed through them, and all best execution data can be found on their website at www.wellsfargoclearingserivcesllc.com, including the current quarter’s data in the Order Routing Information link.
BUSINESS CONTINUITY PLANNING
Trade-PMR 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. Not all elements of the plan are displayed for privacy and other security considerations.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 888-723-3767, you should call our alternative number 352-332-8723 or go to our web site at www.tradepmr.com. If you cannot access us through either of those means, you should contact our clearing firm,Wells Fargo Clearing Services, LLC, at 877-496-3223 or www.wellsfargoclearingservicesllc.com for instructions on how it may provide access to funds and securities, or enter orders.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,Wells Fargo Clearing Services, 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 it has systems and procedures in place to restore its own operations and be able to complete existing transactions and accept new transactions and payments virtually immediately. A copy ofWells Fargo Clearing Services’ BCP policy is available on their web site, www.wellsfargoclearingservicesllc.com.
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, or to our clearing firm if necessary, to recover and resume business. In a disruption affecting our business district, city, or region, we will transfer our operations to our clearing firm until we can recover and resume business. We will promptly notify you of any business disruptions through our web site www.tradepmr.com or our customer emergency number in how to contact us. 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 888-723-3767 or firstname.lastname@example.org.