Registrations & Memberships

  • Corinthian Partners, L.L.C., FINRA CRD # 38912, SEC File # 8-48461.
  • Registered as a broker-dealer with the U.S. Securities and Exchange Commission and as a government-securities broker or dealer.
  • Member, Financial Industry Regulatory Authority (FINRA) since June 25, 1996.
  • Member, Securities Investor Protection Corporation (SIPC).
  • Member, Municipal Securities Rulemaking Board (MSRB).
  • Registered to conduct securities business in thirty-three U.S. states and territories.
  • Clearing & custody through RBC Capital Markets, LLC (CRD # 31194), on a fully disclosed basis.
  • Corinthian Partners Asset Management, LLC, SEC-registered investment adviser affiliated through common ownership with Corinthian Holdings, LLC.

FINRA BrokerCheck

FINRA BrokerCheck is the regulator’s public instrument for researching brokerage firms and their registered personnel. The firm’s record, including any disclosure events, may be reviewed at brokercheck.finra.org under CRD # 38912.

Understanding the Protection of Assets, SIPC and Excess Coverage

RBC Capital Markets, LLC, the firm’s clearing agent, is a member of SIPC, which protects securities clients of its members up to $500,000 (including $250,000 for claims for cash). An explanatory brochure is available on request or at sipc.org.

In addition to SIPC protection, RBC provides excess-of-SIPC coverage from certain underwriters at Lloyd’s, in conjunction with another commercial insurance company. The excess-of-SIPC program provides an aggregate loss limit of $1 billion for eligible securities across all client accounts and a per-client limit of $1.9 million for cash awaiting reinvestment, within the aggregate $1 billion. SIPC and the excess-of-SIPC policy do not protect against loss due to market fluctuation.

Best Execution

Brokers have a duty under SEC and FINRA rules to take reasonable steps to obtain the most favorable terms reasonably available for their clients’ orders. Factors considered in evaluating execution quality include overall market quality and the opportunity for price improvement, speed of execution, order size, the trading characteristics of a particular security, the availability of accurate market information, the availability of economic access to the various market centers, and the cost and difficulty of achieving an execution in a particular venue.

SEC Rule 605, Market-Center Execution Quality

SEC Rule 605 requires “market centers”, exchanges, alternative trading systems, market makers, and OTC dealers that internalize order flow, to publish monthly statistical reports on the quality of executions for NMS stock orders. The reports cover metrics including effective spread, realized spread, price improvement, fill rate, and average execution time.

Corinthian Partners, L.L.C. is an introducing broker-dealer and is not itself a “market center” within the meaning of Rule 605. The firm has no Rule 605 reporting obligation of its own. Rule 605 reports for the market centers that ultimately execute orders routed through RBC Capital Markets, LLC are published by those venues directly, are aggregated for public access through the FINRA 605 NMS Data tool at finra.org/finra-data/605-nms-data, and are reviewed by the RBC Best Execution Committee in connection with the regular-and-rigorous order-routing review described below.

SEC Rule 605, Market-Center Execution Quality

SEC Rule 605 requires “market centers”, exchanges, alternative trading systems, market makers, and OTC dealers that internalize order flow, to publish monthly statistical reports on the quality of executions for NMS stock orders. The reports cover metrics including effective spread, realized spread, price improvement, fill rate, and average execution time.

Corinthian Partners, L.L.C. is an introducing broker-dealer and is not itself a “market center” within the meaning of Rule 605. The firm has no Rule 605 reporting obligation. Rule 605 reports for the market centers that ultimately execute orders routed through RBC Capital Markets, LLC are published by those venues directly and are aggregated for public access through the FINRA 605 NMS Data tool at finra.org/finra-data/605-nms-data and through the websites of individual market centers.

Information about a specific execution venue used to execute a particular client order will be furnished upon written request to the firm.

SEC Rule 606, Order Routing

SEC Rule 606 requires broker-dealers that route customer orders in NMS stocks and listed options to make publicly available quarterly reports describing their order-routing practices. The reports disclose material relationships with significant execution venues and any payment-for-order-flow arrangements. Broker-dealers are also required to disclose, upon a client's request, the venues to which that client's individual orders were routed.

Corinthian Partners, L.L.C. is an introducing broker-dealer; client securities accounts are carried on a fully disclosed basis by RBC Capital Markets, LLC. The firm transmits all client equity and listed-option orders to RBC, which determines where each order is executed. Because RBC is the routing broker for those orders, RBC produces and publishes the Rule 606 quarterly reports applicable to them.

RBC’s current Rule 606 disclosures are available on the RBC Capital Markets regulatory disclosures page at RBC Capital Markets, Regulatory Disclosures, Equities and Listed Options (PDF). The corresponding 606(a) and 606(b) data are also accessible through the FINRA 606 NMS Data tool at finra.org/finra-data/606-nms-data. A written copy of RBC’s current Rule 606 report, and information regarding the routing of specific orders executed for a client account, will be furnished upon request to the firm.

RBC Clearing & Custody Best Execution Committee

RBC Clearing & Custody maintains a Best Execution Committee comprised of senior management from RBC C&C Operations and Finance. The Committee meets monthly to review statistics and other information bearing on the execution quality provided by RBC’s order-routing destinations and competing venues. The review is mandated by RBC C&C’s written supervisory procedures and uses the execution statistics required to be published by market centers under SEC Rule 605 and Rule 606, as provided to RBC by S3 Matching Technologies, LP.

In addition to reviewing statistics, the Committee also reviews RBC’s order-routing processes and technology and may recommend improvements to or replacement of the routing systems in use.

Corinthian’s Independent Best-Execution Review

FINRA has stated that no member can transfer its best-execution obligation to another member, and that an introducing broker-dealer must take reasonable steps to ensure that the introducing broker-dealer and its executing broker-dealer are complying with the duty of best execution. As FINRA noted in NASD Notice to Members 01-22, an introducing firm that routes its order flow to its clearing firm may rely on the clearing firm’s regular-and-rigorous review so long as the statistical results and rationale of the review are fully disclosed to the introducing firm and the introducing firm periodically reviews how the clearing firm is conducting that review and the results.

Corinthian Partners, L.L.C. follows that path. At this time, Corinthian Partners routes all of its order flow under RBC Clearing & Custody’s standard order-routing tables. The firm relies on RBC’s regular-and-rigorous review of those routing tables and the resulting execution statistics, and the firm separately, and periodically, reviews both the methodology of RBC’s review and the statistical results, as required by FINRA. The firm does not currently maintain a customized RBC routing table, does not direct a material number of orders “away” from RBC’s standard routing, and does not direct a material number of orders through RBC to specific destinations of its own selection. The firm’s practice is to route on the standard tables, period.

If any of the foregoing changes, for example, if the firm’s Institutional Trading desk or any other business line begins routing through a customized table, directing material order flow away from RBC’s standard routing, or directing material order flow to specific destinations of the firm’s own selection, this disclosure will be updated to reflect the change, and the firm’s independent best-execution review will be expanded accordingly. Until then, the disclosure on this page is the firm’s current and accurate posture.

A written copy of RBC’s current Rule 606 report, the FINRA 605 and 606 data summarized for orders cleared by RBC, and information regarding the routing of specific orders executed for a particular client account, are available upon written request to the firm.

Material Relationship with RBC Capital Markets, LLC

Corinthian Partners, L.L.C. is an introducing broker-dealer. Securities accounts opened by clients of the firm are carried on a fully disclosed basis by RBC Capital Markets, LLC (“RBC”), specifically by RBC’s clearing-and-custody division (“RBC Clearing & Custody” or “RBC C&C”). RBC handles the execution, clearance, settlement, custody, statement and trade-confirmation production, regulatory reporting, and tax-document preparation for those accounts under a written clearing agreement.

Other than the clearing arrangement and the standard correspondent broker-dealer relationship that follows from it, Corinthian and RBC are not affiliated. RBC’s execution and routing decisions, the order-routing inducements that may apply to RBC, and any payments RBC receives for order flow, are governed by RBC’s policies and disclosed in RBC’s Rule 606 reports rather than in any disclosure of the firm’s own.

Comprehensive RBC C&C disclosures, including margin, customer-information brochures, account agreements, sweep program details, and tax-form information, are maintained on the RBC Clearing & Custody legal page at rbcclearingandcustody.com/en-us/legal.

USA PATRIOT Act and Customer Identification Program

Federal law requires all U.S. financial institutions to obtain, verify, and record information that identifies each person who opens an account. When a client opens an account with the firm, the firm collects the client’s name, date of birth, address, taxpayer-identification number, and other information that allows the firm to identify the client. The firm may also ask to see a driver’s license, passport, or other identifying documents.

Information collected pursuant to the firm’s Customer Identification Program is used in connection with the firm’s anti-money-laundering compliance program and is treated in accordance with the firm’s Privacy Notice and applicable law.

Anti-Money Laundering

Corinthian Partners maintains a written Anti-Money Laundering (AML) program reasonably designed to comply with the Bank Secrecy Act, the USA PATRIOT Act, and FINRA Rule 3310. The program covers customer identification, ongoing client due diligence, sanctions and Politically Exposed Person screening, suspicious-activity monitoring and reporting, recordkeeping, and annual independent testing. Questions regarding the firm’s AML program may be directed to the Office of the Chief Compliance Officer through the contact form.

Margin Disclosure Statement

Securities purchased on margin are the firm’s and RBC’s collateral for the loan. If the securities in a client’s account decline in value, so does the value of the collateral, and RBC can take action, including issuing a margin call and selling securities or other assets in the client’s account, in order to maintain the required equity in the account. Clients are not entitled to choose which securities or other assets are sold, are not entitled to an extension of time on a margin call, and may not be contacted before action is taken. RBC may also increase its “house” maintenance-margin requirements at any time and is not required to provide advance written notice. The full Margin Disclosure Statement and the Margin Account Agreement are provided by RBC at account opening and are available on the RBC Clearing & Custody legal page; clients are urged to read them carefully before trading on margin.

Day Trading Risk Disclosure

Day trading can be extremely risky. It generally is not appropriate for clients with limited resources, limited investment or trading experience, or low risk tolerance. A client should be prepared to lose all of the funds used for day trading. Day trading requires knowledge of the securities markets, knowledge of the firm’s and RBC’s business practices, including operation of order-execution systems and procedures, and constant monitoring of the markets. Day trading generally also involves significant commissions, fees, and other transaction costs, all of which reduce profitability. Clients designated as “pattern day traders” under FINRA Rule 4210 are subject to higher minimum-equity requirements and other restrictions. The full Day Trading Risk Disclosure is delivered at account opening for accounts approved for day trading.

Bank Deposit Sweep Program and Free Credit Balances

Free credit balances in eligible client accounts may be automatically deposited (“swept”) through the RBC Bank Deposit Sweep Program into one or more interest-bearing accounts at FDIC-insured depository institutions, subject to applicable program terms and FDIC insurance limits. Sweep balances at participating FDIC-insured banks are eligible for FDIC insurance up to the standard maximum deposit-insurance amount per depositor, per insured bank, for each ownership category. Cash balances awaiting sweep, and balances in excess of FDIC insurance limits, are protected by SIPC and the supplemental excess-of-SIPC coverage referenced above, subject to the limits of those programs.

Full details of the Bank Deposit Sweep Program, including a current list of participating banks, applicable interest rates, the order in which deposits are made and withdrawn, and the relevant disclosures, are available on the RBC Clearing & Custody legal page and in the program documents delivered at account opening.

Mutual Fund Breakpoint Disclosure

When a client purchases mutual fund Class A shares (and certain other share classes) of a fund family, the client may be entitled to a discount on the front-end sales charge known as a “breakpoint discount.” Breakpoint discounts apply at specified investment levels, and certain rights, the “Right of Accumulation” and the “Letter of Intent,” can allow a client to combine current and prior purchases, and to aggregate purchases across related accounts, to qualify for a discount. To assist the firm in identifying the breakpoint discounts available, clients should provide complete information about all related fund holdings, including holdings at other broker-dealers and at the fund company directly. The fund prospectus and Statement of Additional Information set out the precise breakpoint schedule, and the FINRA Mutual Fund Breakpoint Search tool is publicly available.

Penny Stock Risk Disclosure

“Penny stocks,” defined under SEC Rule 3a51-1, are typically low-priced equity securities of small companies that may have limited or no quoted market and that may be subject to substantial price volatility. The risks of investing in penny stocks include limited liquidity, less reliable information, susceptibility to market manipulation, and potential loss of the entire investment. Clients approved to trade penny stocks receive the SEC-required Penny Stock Risk Disclosure Statement before any penny-stock transaction, and a separate written suitability determination is documented for each recommended penny-stock purchase.

Cost-Basis and 1099 Reporting

Cost-basis information for covered securities is maintained and reported by RBC, as the carrying broker, in accordance with the cost-basis reporting rules under Internal Revenue Code Sections 6045 and 6045A. Annual Form 1099 statements (Form 1099-B for sales, Form 1099-DIV for dividends, Form 1099-INT for interest, Form 1099-OID for original issue discount, and Form 1099-MISC where applicable) are produced and delivered by RBC. Clients with questions about the calculation, classification, or reporting of cost basis or any 1099 entry should contact their named Corinthian advisor in the first instance, who will coordinate with RBC’s tax-reporting team.

Variable Annuity and 529 Plan Disclosures

Variable annuities and 529 college-savings plans are sold only by prospectus. The applicable prospectus contains the security’s investment objectives, risks, charges, and expenses, and other important information that should be read carefully before investing. The firm delivers the prospectus before, at, or with the confirmation of the transaction, as required by applicable rules, and any recommendation of a variable annuity or 529 product is made under the firm’s suitability and Regulation Best Interest framework.

Form CRS and Regulation Best Interest

When the firm makes a recommendation to a retail customer with respect to a securities transaction or investment strategy, it does so under the standard of care established by Regulation Best Interest. The current Form CRS is available for download below.

Order-Routing Reports and Key Disclosures

The canonical Rule 606 order-routing reports for orders cleared by RBC Clearing & Custody, hosted by their disclosure vendor S3 Matching Technologies, LP, are available at the link below. Form CRS, the RBC Fees Schedule, and the full RBC C&C Legal Disclosures hub are linked alongside.

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