MORETON CAPITAL MARKETS, LLC, CUSTOMER INFORMATION ANNUAL 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.
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.
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
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)
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.
If you are an individual or open an account or carry out transactions with Moreton Capital Markets, Moreton Capital Markets may collect the following information:
Date of birth
U.S. citizen: taxpayer identification number (Social Security number or employer identification number)
Non-U.S. citizen: taxpayer identification number; passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you.
The firm may also collect other information such as place of employment, investing history, and other information as deemed necessary or appropriate.
You may also need to show your driver's license or other identifying documents.
If you are a corporation, partnership, trust or other entity opening accounts with Moreton Capital Markets, Moreton Capital Markets asks for (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, they may have to close it.
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, 303-220-1600, 952-777-2626, or by email: firstname.lastname@example.org. 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 Denver, 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 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: email@example.com
Payment for Order Flow Practices SEC Rule 607
As a matter of policy Moreton Capital Markets does not receive payment in return for directing customer equity order flow to particular market centers. Moreton Capital Markets sends certain equity orders to exchanges, electronic communication networks, or broker-dealers during normal business hours. Some of these market centers provide credits to Moreton Capital Markets or charge access fees depending upon the characteristics of the order and any subsequent execution. Disclosure of order flow can be provided by your Moreton Capital Markets representative.
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.
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.
Types of Nonpublic Personal Information We Collect
We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization, including: Name, address, phone number, social security number, age, birth date, citizenship, identification number such as driver’s license or passport.
Moreton Capital Markets, LLC considers your financial data to be private and confidential, and we hold ourselves to the highest standards of trust in their safekeeping and use.
In our day-to-day business there can be a need to share information with our affiliates, (Moreton & Co and Moreton Asset Management, LLC), as well as non-affiliated companies that you have chosen to do business with, such as RBC CS MCM’s clearing firm. This information could consist of Public Information, such as that listed in a phone book, or Nonpublic Information, such as your social security number, date of birth, identification number, etc. We want you to know how we handle and protect your nonpublic information:
How do we receive your nonpublic personal information:
We receive information from you on applications or other forms, and we may receive information from our affiliates, your broker/dealer or insurance company.
Why do we collect your nonpublic information:
Regulatory Authorities require information be obtained from our clients in accordance with our broker/dealer agreement, as well as our contracts with your broker/dealer or insurance company. We also document and verify your identification in accordance with the Federal Anti-money laundering identification program.
We do not disclose nonpublic personal information about our clients or former clients to anyone, except as permitted by law. Moreover, we will not release information about our clients or former clients unless one of the following conditions is met: We receive your prior written consent; We believe the recipient to be you or your authorized representative; We are required by law to release information to the recipient.
As part of servicing or maintaining your contract or account with your broker/dealer or insurance company, and for other legally permitted or required purposes, we may disclose your non-public personal and health information, if applicable. This may include providing such information to service providers working with us, to your agent or broker, or for financial planning purposes.
Confidentiality and Security
We maintain physical, electronic and procedural safeguards to guard your personal information. We also restrict access to your personal data to authorized Moreton Capital Markets, LLC associates who have a need for these records. We require all nonaffiliated organizations to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after our association has ended or becomes inactive.
We do not sell client information to third parties or outside parties who may wish to market their products to you. We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.
You have the right to opt-out of our sharing your personal information to service providers by sending request to firstname.lastname@example.org or calling 952-777-2626. (Note, any previous opt-out that you may have submitted is in place until you reverse your decision)
Moreton Capital Markets, LLC 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: When you open an account as an individual investor we will ask for your name, address, date of birth and identification number. For a non-citizen the identification number would include the taxpayer identification number, passport number, and country of issuance, alien identification number, or government-issued identification showing nationality, residence, and photograph of you. We may ask to see your driver’s license or other identifying documents. A corporation, partnership, trust or other legal entity may need to provide other information, such as 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.
Parties to Whom We Disclose Information
For current and former clients, we do not disclose any nonpublic personal information obtained in the course of our business except as required or permitted by law or with affiliated entities and service providers that have been identified. Permitted disclosures include, for instance, providing information to our employees and, in limited situations, to unrelated third parties who need to know that information to assist us in providing services to you. In all such situations, we stress the confidential nature of information being shared. Moreton Capital Markets may also share information with its affiliate.
Protecting the Confidentiality and Security of Current and Former Client's Information
We retain records relating to professional services that we provide so that we are better able to assist you with your professional needs and in some cases, to comply with professional guidelines. In order to guard your nonpublic personal information, we maintain physical, electronic and procedural safeguards that comply with our professional standards.
RBC Correspondent Services
Please call if you have any questions, or want to opt out of our information sharing, because your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us. you may opt out of information sharing via email to email@example.com or by calling 952-777-2626.
If there is anything that has not been addressed by the above, please contact the Compliance Department at firstname.lastname@example.org 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.