Legal, Regulatory Disclosures, and Business Continuity

Membership

Municipal Securities Rulemaking Board – MSRB

Securities Investor Protection Corporation – SIPC

Financial Industry Regulatory Authority – FINRA

Clearing Agent

RBC – Clearing & Custody

Understanding the Protection of Assets

Securities Investor Protection Corporation (SIPC®) Coverage

RBC is a member of SIPC, which protects securities clients of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at SIPC.

Excess of SIPC Coverage Led by Lloyd’s

In addition to SIPC protection, RBC provides coverage in excess of SIPC limits from certain underwriters at Lloyd’s, in conjunction with another commercial insurance company.1 The excess of SIPC insurance program is valid through February 10, 2014 for RBC accounts. It provides the following protection for RBC’s global client assets:

  • An aggregate loss limit of $1 billion for eligible securities—over all client accounts
  • A per-client loss limit of $1.9 million for cash awaiting reinvestment—within the aggregate loss limit of $1 billion

SIPC and the excess of SIPC insurance policy do not protect against loss due to market fluctuation.

An excess of SIPC claim would only arise if RBC failed financially and client assets for covered accounts—as defined by SIPC—cannot be located due to theft, misplacement, destruction, burglary, robbery, embezzlement, abstraction, failure to obtain or maintain possession or control of client securities, or to maintain the special reserve bank account required by applicable rules.

The leader of the excess of SIPC coverage program is Lloyd’s, which currently holds A+ ratings from Fitch Ratings and Standard & Poor’s® (S&P®), and an A rating from A.M. Best. These ratings are based on the financial strength of the company and are subject to change by the rating agencies at any time.2 For more information about Lloyd’s, please see www.lloyds.com.

SEC Rule 606

SEC Rule 606 (formerly SEC Rule 11 Ac1-6) requires all broker-dealers that route orders in equity and option securities to make available quarterly reports that present a general overview of their routing practices.

The rule also requires that the report disclose any “material aspects” of our relationship with significant execution venues and a description of any payment for order flow arrangements. In addition, we are required to disclose to our clients, upon their request, the venues to which their individual orders were routed. Corinthian Partners, LLC (“CP, LLC”) has a fully disclosed clearing agreement with RBC. CP, LLC pays a clearing fee to RBC for services it performs such as transaction settlement, extending credit, maintaining custody of client securities and funds, and statements. CP, LLC transmits all of its RBC client equity and option orders directly to RBC. RBC determines where to execute your order. Please Click Here then enter “Broker-Dealer’s Full Name:’ as “Corinthian Partners L.L.C.” to view the Order Routing Disclosure compiled by RBC. A written copy of this report will be furnished upon request. Any information regarding specific routing or any orders executed for your account will be furnished upon request.

Privacy Policy

Corinthian Partners, L.L.C. (“Corinthian Partners”) privacy policy applies to consumers who are current or former Corinthian Partners clients or who register for one of our services or promotional offers. Throughout the policy, we refer to information that personally identifies you or your accounts as “personal information.”

  1. We do not sell your personal information to anyone.
  2. We do not disclose personal information to third parties, unless one of the following limited exceptions applies. We disclose personal information to companies that help us process or service your transactions or account(s), including companies that print and mail your account statements. So that you can learn about products or services, we also may disclose personal information, such as account and transaction data, to companies, including financial institutions, which assist us in marketing. We have contracts with these companies that prohibit them from using your personal information for their own purposes. We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, resolve consumer disputes, perform credit/authentication checks, or for institutional risk control. Outside of these exceptions, we will not share your personal information with third parties unless you have specifically asked us to do so, that is, opted-in.
  3. We do collect personal information in the normal course of business in order to administer your accounts and serve you better.

Application and registration information. We collect information that you provide to us when you open an account or register for one of our services, such as online or branch seminars, or when you accept a promotional offer for a Corinthian Partners-sponsored product or service. The information we collect may include name, address, phone number, email address, social security number, and information about your interests, investments, and investment experience. We also may collect information from consumer reporting agencies.

Web site usage. We collect some information on our Web sites through the use of “cookies.” For example, we may identify the pages on our Web sites that your browser requests or visits. This information is only personally identifiable if you have chosen to identify yourself.

Transaction information. Once you have an account with us, to administer your account and better serve you, we collect and maintain personal information about your transactions, including balances, positions, and history, and may include your name or other data in an internal client list that reflects your activities at Corinthian. As part of our efforts to reach and serve new and existing clients we sometimes collect and use information from outside mailing lists.

  1. We use your personal information to fulfill our regulatory obligations and to help us deliver the best possible service to you. For example, we may use your personal information to provide faster more convenient services or to alert you to Corinthian Partners products and services you may find useful. To understand your financial needs and to deliver financial products and services that meet them, we may share personal information, such as transaction or experience data, with these affiliates, all of which follow similar privacy policies.
  2. We protect the confidentiality and security of your personal information. Companies we hire to provide support services are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested. We restrict access to personal information to our employees and agents for business purposes only. All employees are trained and required to safeguard such information. We maintain physical, electronic, and procedural safeguards to guard your personal information.
  3. We continue to evaluate our efforts to protect personal information and make every effort to keep your personal information accurate and up to date. If you identify any inaccuracy in your personal information, or you need to make a change to that information, please contact us so that we may promptly update our records.
  4. We will provide notice of changes in our information-sharing practices. If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you will have the opportunity to opt-out of such disclosure. If you have any questions or concerns, please contact us by e-mail at mmanoff@corinthianpartners.com or call us at 1-800-899-8950.

The Client Account Access is the area of our Web Site available only to account holders. The Access Center provides a private and secure Web environment to place trade orders and access account information. Logging-in to the Access Center requires both a personal account number and a password individually selected by each customer. The Access Center uses leading encryption technology so that the data we transmit to you and the data you transmit to us across the Internet are safe. Secure data includes account information, trade orders, and e-mail sent from within the Access Center.

Business Continuity

Corinthian Partners, L.L.C. 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 (800)-899-8950, you should call our alternative number (516)-458-1158 or go to our website. If you cannot access us through either of those means, you should contact our clearing firm, RBC, at (201)-413-2000 for instructions on how you may gain prompt access to funds/securities, process trades, or transfer cash/securities. You must have your account number available.

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, RBC, 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 within a reasonable amount of time. 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 the day. 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 within a two (2) day period. In either situation, we plan to continue in business and notify you through our web site www.corinthianpartners.com or our customer emergency number (516) 458-1158. 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 any questions about our business continuity planning, you can contact Mitchell Manoff at 212-287-1552 or email mmanoff@corinthianpartners.com.

Pandemics, Epidemics, & Outbreaks

Corinthian Partners/Corinthian Partners Asset Management LLC., CP/CPAM recognizes that pandemics, epidemics, and other types of outbreaks constitute business disruptions of a special nature. These situations impact not only CP/CPAM as a company, but also its personnel, clients, and vendors. Accordingly, CP/CPAM intends to implement the following procedures during such a situation.

General Business Operations

Promptly, and then intermittently thereafter, CP/CPAM will conduct a high-level assessment of the situation’s impact on business and operations. Specifically, CP/CPAM will identify and address:

  • any weaknesses or unforeseen issues
  • any inability to conduct essential operations or operate essential systems
  • any inability to monitor third party vendors

Information Security & Remote Operations

CP/CPAM will also alert personnel to the increase likelihood of phishing attempts and client impersonation schemes related to the situation. For example, bad actors may target individual staff members with requests for wire transfers posing as a client, emails related to state or federal work from home updates, changes to healthcare benefits, changes in information security policy related to working from home, software required to install on computers in order to work from home, the latest epidemic statistics, or even discounted offers on items in short supply. Accordingly, the firm will refer personnel to CP/CPAM’s cybersecurity best practices and ensure that those practices are up to date.

If necessary, CP/CPAM will also conduct training for its personnel to address (i) potential information security issues commonly associated with remote work and (ii) the importance of protecting non-public client information at all times. In particular, advisory personnel are instructed to:

  • access the internet only from secure Wi-Fi connections or via a virtual private network (“VPN”)
  • avoid using public Wi-Fi networks, which are vulnerable to exploitation
  • store any sensitive, non-public information on non-company devices only after taking the proper security protections and obtaining authorization

If having personnel work remotely, then CP/CPAM will also:

  • catalogue systems that cannot be accessed remotely, if any
  • shut down non-essential hardware (e.g., computers)
  • lock its physical storage (e.g., file cabinets) and all office access
  • check in with building management, if applicable, to determine current security at the facility
  • require that firm personnel continue following advertising guidelines for applicable communications
  • ensure electronic cataloguing of communication is still taking place
  • continue to document all interactions with clients, regardless of the medium of interaction
  • update CP/CPAM’s business continuity plan as needed

Third Party Vendors

If appropriate, CP/CPAM will endeavor to discuss with vendors the following:

  • the vendor’s business continuity efforts
  • the vendor’s disaster recovery plans
  • the vendor’s reliance on, and communications to date with, the vendor’s vendors

Company Personnel

If appropriate, CP/CPAM will limit or altogether avoid in-person meeting with clients and advisory personnel and allow or require (as appropriate) personnel to work remotely. Any personnel that is limited in their ability to work remotely, will immediately inform their supervisor. Limitations include but are not limited to:

  • Inadequate hardware, software, or other systems
  • Need to perform caregiving services for children or other persons
  • Physical incapacity

If essential personnel are limited in their ability to work remotely, then the firm will determine if alternate or temporary personnel are available to perform necessary functions. Additionally, CP/CPAM will conduct check-ins with advisory personnel no less than weekly regarding remote work conditions.