Membership

• Municipal Securities Rulemaking Board – MSRB
• Securities Investor Protection Corporation – SIPC
• Financial Industry Regulatory Authority – FINRA

Clearing Agent

RBC – Clearing & Custody

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 Capital Markets, LLC maintains supplemental coverage in excess of SIPC limits from certain underwriters at Lloyd’s of London, in conjunction with another commercial insurance company.¹ The supplemental program provides the following protection for RBC’s eligible 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.

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 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

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. Reported metrics include 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.

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

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.

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

CP, LLC’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.

CP, LLC follows that path. The firm relies on RBC’s regular-and-rigorous review for the order flow that CP, LLC routes to RBC under RBC’s standard order-routing tables, and CP, LLC periodically reviews both the methodology of RBC’s review and the statistical results, as required by FINRA. CP, LLC does not 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. Were the firm to do any of those things, additional independent review would be required.

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 CP, LLC 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 execution, clearance, settlement, custody, statement and trade-confirmation production, regulatory reporting, and tax-document preparation under a written clearing agreement. Other than the clearing arrangement, CP, LLC and RBC are not affiliated.

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. CP, LLC collects the client’s name, date of birth, address, taxpayer-identification number, and other identifying information at account opening, and 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 Policy and applicable law.

Anti-Money Laundering

CP, LLC maintains a written Anti-Money Laundering 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 CP, LLC’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 account, in order to maintain the required equity. 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.

Day Trading Risk Disclosure

Day trading can be extremely risky and is generally not appropriate for clients with limited resources, limited investment or trading experience, or low risk tolerance. Day trading requires knowledge of the securities markets, knowledge of the firm’s and RBC’s business practices, and constant monitoring of the markets, and it generally involves significant commissions, fees, and other transaction costs that 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 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 the “Right of Accumulation” and “Letter of Intent” can allow combining current and prior purchases, and aggregating purchases across related accounts, to qualify for a discount. 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 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 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 CP, LLC 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. CP, LLC delivers the prospectus before, at, or with the confirmation of the transaction, and any recommendation of a variable annuity or 529 product is made under the firm’s suitability and Regulation Best Interest framework.

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.”

• We do not sell your personal information to anyone.
• 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.
• 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.

• 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.
• 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.
• 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.
• 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 reach the firm through the contact form or call us at 212-287-1500.

 

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 212-287-1500, 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 through the contact form.

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.