Privacy Policy & Disclosures
MORETON CAPITAL MARKETS, LLC, CUSTOMER INFORMATION DISCLOSURES
Moreton Capital Markets, LLC (“MCM” or the “Firm”) would like to take this opportunity to thank you for your continued business and we look forward to continuing to provide the highest level of service in the future. This disclosure is provided in order for Moreton Capital Markets to remain compliant with a number of customer account disclosure requirements. This notification is for informational purposes and does not require any action on your part.
MSRB Notice
Please be advised that Moreton Capital Markets is registered with the U.S. Securities and Exchange Commission ("SEC")and the Municipal Securities Rulemaking Board ("MSRB"). The MSRB makes available to investors through its website (www.msrb.org) certain information, including but not limited to, an investor brochure that describes the protections that may be provided by the MSRB rules and how to file a complaint with the appropriate regulatory agency.
SIPC notice
Moreton Capital Markets is a member of the Securities Investor Protection Corporation (“SIPC”). FINRA Rule 2266 requires Moreton Capital Markets to disclose SIPC Contact Information. SIPC plays an important role in the overall system of investor protection in the United States by, in certain specified situations, restoring funds to investors with assets in the hands of bankrupt and otherwise financially troubled brokerage firms. When a brokerage firm is closed due to bankruptcy or other financial difficulties and customer assets are missing, SIPC steps in as quickly as possible and, within certain limits, works to return customers’ cash, stock, and other securities. You may obtain more information about SIPC, including a brochure entitled How SIPC Protects You, by contacting SIPC at:
Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215
phone: (202) 371-8300
Email: asksipc@sipc.org
You may also visit SIPC's website at www.sipc.org
FINRA Regulation Public Disclosure Program
Moreton Capital Markets is required by FINRA Rules to provide you with information about the availability of information through FINRA's Public Disclosure Program. The investor brochure may be obtained via the FINRA website (www.finra.org) or through the FINRA Public Disclosure Program Hotline Number at (800) 289-9999.
Important Information about New Account Opening Procedures / Customer Identification Program (CIP)
To help fight the funding of terrorism and money-laundering activities, U.S. federal law requires financial institutions to obtain, verify and record information that identifies each customer (individuals and businesses). When you establish a new relationship we will ask for your name, address, tax identification number, and other information that will allow us to identify you. As part of this process we may also ask to see identifying documents. The information that we obtain will be used to verify your identity in accordance with provisions of the USA PATRIOT ACT Section 326.
The USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) was enacted to strengthen the United States government's ability to combat terrorist financing and money laundering. An essential component of the USA PATRIOT Act requires financial institutions to obtain, verify and record information that identifies each person or entity with an account relationship at a financial institution.
A corporation, partnership, trust or other entity opening accounts with Moreton Capital Markets may be required to provide (i) name, (ii) street address (either principal place of business, a local office or other physical location), (iii) a U.S. taxpayer identification number, or if not organized or a resident in the United States or filing U.S. income tax returns, the number and country of issuance of any other government-issued document certifying the existence of the organization, and (iv) such other information or documents that we consider necessary to verify the entity's identity. Examples of additional information include articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument. We may also verify the entity's identity through other means.
If the above information is not provided, Moreton Capital Markets may not be able to open an account or carry out transactions for you. If Moreton Capital Markets has already opened an account for you, and the necessary information has not been received, the account may be closed.
Business Continuity Planning
MCM 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 are unable to reach us at the numbers you would normally use, you can contact us at (801) 535-3650, 213-223-2059, 952-777-2626, or by email: team@moretoncm.com. In the event you are unable to access us by any of the aforementioned means you may also contact your MCM representative by e-mail or cell phone.
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. 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 clients, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting.
Varying Disruptions – Significant business disruptions can vary in 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 either our local area, or regional area, we will transfer our operations to a site outside the affected area. Our office locations include Salt Lake City and Los Angeles, and we have capability to conduct business from Minneapolis as well as several other remote locations. Our recovery time objective is within one business day. We plan to continue business and notify you through our client emergency number: 952-777-2626. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our clients prompt interface with the respective companies and entities that have provided investment products to you. We will also update our voice message.
If you would like a copy of the full plan, please contact your Moreton Capital Markets representative.
Complaints
Complaints concerning services provided by Moreton Capital Markets may be directed to:
Moreton Capital Markets Compliance Department
101 South 200 East, Suite 300
Salt Lake City, UT 84111
Or by calling: 952-777-2626, or email to: eric@moretoncm.com
Payment for Order Flow Practices SEC Rule 607
Moreton Capital Markets does not receive payment in return for directing customer equity order flow to particular market centers.
SEC Rule 606 Disclosure of Order Routing Practices
SEC Rule 606 requires all broker-dealers (including introducing firms) that route customer orders in equity and option securities are required to make publicly available quarterly reports that, among other things, identify the venues to which customer orders are routed for execution and also disclose the material aspects of the broker-dealer's relationship with such venues. Moreton Capital Markets does not provide order routing services. Equity orders are routed to RBC, and routing reports can be found at this link.
Confidentiality
Moreton Capital Markets’ policy is to maintain the confidentiality of client order and transaction information. Please be assured that Moreton Capital Markets has strict policies and procedures in place for the confidentiality of client information, as well as, sophisticated and secure trading and operational technology to provide superior protection of our clients’ portfolio holdings and related trading activity.
Moreton Capital Markets’ Privacy Policy
GRAMM-LEACH BLILEY ACT AND SEC REGULATION S-P and REGULATION S-AM requires Moreton Capital Markets to disclose its privacy policy.
Customer Information Safeguarding Statement
Moreton Capital Markets exclusively provides services to institutional investors. While we do not have natural person customers, we acknowledge our obligation under Regulation S-P to protect the nonpublic personal information (NPI) of natural persons that we may receive from our institutional clients, clearing firms, or other third-party institutions. We may also collect NPI about individuals associated with your account, such as authorized representatives.
Confidentiality and Security
We may share NPI with our affiliate, (Moreton & Co), as well as non-affiliated companies in need of the information such as RBC CS, our clearing firm. This NPI may be received from you on applications or other forms.
We maintain physical, electronic, and procedural safeguards that comply with professional standards and regulatory mandates to guard this personal information. These safeguards include:
IRP and Notification: We maintain an Incident Response Program (IRP) designed to detect, respond, and recover from unauthorized access to all customer information we possess, and notify affected individuals as required (within 30 days if sensitive information is involved).
Service Provider Requirements: We require all third-party service providers and non-affiliated organizations to conform to our privacy standards and require notification within 72 hours of detecting a breach involving customer information.
Disposal: We securely dispose of customer and consumer information to prevent unauthorized access.
Access Restriction: We restrict access to all nonpublic personal data to only authorized associates who have a need for these records. We do not sell client information to third parties who may wish to market their products to you. We may share with affiliates as disclosed.
Why do we collect your nonpublic information: Regulatory Authorities require certain information to be obtained. We also document and verify your identification in accordance with the Federal Anti-money laundering identification program.
Customer Identification Program Notice: 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: A corporation, partnership, trust or other legal entity may need to provide its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement. Should you have any questions contact Moreton Capital Markets at 801-535-3650, 101 South 200 East Suite 300, Salt Lake City, Utah 84111.
RBC Correspondent Services: Our firm has a contractual agreement with RBC Correspondent Services to serve as our clearing firm. RBC privacy policies can be found here. Responsibilities of Moreton Capital Markets and RBC can be found here.
product information and disclosures
Government Sponsored Enterprises
If there is anything that has not been addressed by the above, please contact the Compliance Department at eric@moretoncm.com or 952-777-2626.
Products offered through Moreton Capital Markets, LLC are not FDIC Insured, Not Guaranteed, and May Lose Value. Past performance is not indicative of future results.