General Disclosures
Business Continuity
In the event of a significant business disruption, Wall Street Access will employ a business disruption plan that may involve certain employees being relocated to its disaster recovery facility. Depending on the severity of the disruption, designated employees have been selected to contact certain customers and to provide them with information regarding their account or where they may be able to access information regarding their account. The Wall Street Access Business Continuity Plan provides for two scenarios: business disruption to its on-site location, by whatever means, or a business disruption of the markets and/or the area surrounding its location. During either scenario, Wall Street Access plans to continue doing business and in the first scenario, its planned recovery time is expected to be within an hour and in the second scenario, its planned recovery time is expected to be within three hours.
Wall Street Access intends to notify its customers by phone or by its web site and such notification will include how customers can access their account and notification of the appropriate regulatory bodies.
Wall Street Access’s business disruption plan is subject to modification. Any updated plans will promptly be posted on its Internet website, and that customers may alternatively obtain updated plans via www.wsaccess.com or by requesting a written copy of the plan by mail.
Privacy and Security Policy Statement
As a financial institution and member of the NYSE, FINRA and SIPC, Wall Street Access and its affiliated entities (“WSA” or “We”) must obtain personal and financial information about its customers. WSA does not collect nonpublic personal information from consumers until they become customers of WSA. Individuals do not become consumers of WSA by merely providing names, addresses, and general areas of investment interest. The purpose of the information that we collect is to assist us in better servicing your account and investment needs. We recognize and understand the importance that each of our customers places on the privacy and security of such nonpublic personal information. Therefore, we take every reasonable precaution to ensure that this information is safe and secure while in transit to us and while stored on our systems. Similarly, we will maintain the confidentiality of such nonpublic personal information in accordance with the following terms of this Privacy Policy.
Collection of Nonpublic Personal Information
WSA limits the collection and use of nonpublic personal information to that which is necessary to effectively administer our business, delivers exceptional service to our customers, and comply with applicable industry regulations. We collect nonpublic personal information about you from the following sources:
- Information we receive from you on applications and other forms;
- Information about your transactions with us, our affiliates, or others; and
- Information we may receive from a consumer-reporting agency.
Use of Nonpublic Personal Information
WSA does not sell nonpublic personal or financial information about our customers or former customers. WSA also does not disclose any nonpublic personal information about our customers or former customers to any nonaffiliated third parties, except as described below:
WSA may provide its customers with the opportunity to participate in promotions and special offers for investment related products through joint marketing arrangements with affiliates and third party service providers. Your participation in these offers may require us to share data with these third parties (such as name, address, phone number or email address, or the number of WSA customers who participate in the promotion or special offer). All parties to such joint marketing arrangements are bound by obligations of confidentiality not to disclose any information provided by WSA about its customers and may not use such information for any purposes other than the performance of the particular service covered by the joint marketing arrangement. If you wish to permanently opt-out of these offers, please contact us via email at privacy@wsaccess.com or call us at 1-800-758-5195.
WSA may enter into joint marketing relationships with affiliated and non-affiliated financial service providers that involve sharing personal information about customers in order to provide particular products or services WSA believes will be of interest to its customers. Such information may include customer name, address, phone number, or email address. All parties to such joint marketing arrangements are bound by obligations of confidentiality not to disclose any information provided by WSA about its customers and may not use such information for any purposes other than the performance of the particular service covered by the joint marketing arrangement.
WSA may use third party service providers for several purposes, including the analysis of customer information for internal marketing purposes, printing, fulfillment, etc. The third party service providers are bound by obligations of confidentiality not to disclose any information provided by WSA about its customers and may not use such information for any purposes other than the performance of the particular service for which they have been contracted.
WSA also reserves the right to disclose or report nonpublic personal information in limited circumstances where we believe in good faith that such disclosure is permitted or required by law, to cooperate with regulators or law enforcement authorities, to perform any necessary credit checks, to collect or report debts owed to us, or to protect our rights or property.
Information Security
We restrict access to nonpublic personal information about you to those WSA employees who have a need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
Correcting and Updating Your Information
The accuracy of your personal information is important to us and will facilitate our ability to provide you with the excellent service that you expect and deserve. If you are a customer and have a concern or questions about the accuracy or currency of your personal or account information maintained at WSA, please contact us via email at Contact@wsaccess.com or call WSA customer service at 1-800-758-5195.
If you have questions about our privacy policy, please contact us via email at Contact@wsaccess.com or call WSA customer service at (800) 758-5195.
Financial Industry Regulatory Authority (FINRA) Public Disclosure
Pursuant to FINRA Rule 2267, Wall Street Access is required to provide you with the following information:
- The FINRA Public Disclosure Hotline Number is (800) 289-9999
- The FINRA Web Site address is www.finra.org
- An Investor Brochure describing the FINRA Public Disclosure Program is available. Customers can request a copy of the brochure using the FINRA Public Disclosure Hotline Number noted above or by accessing the FINRA Web Site noted above,
Securities Investor Protection Corporation (SIPC)
Customers can obtain information about SIPC, including the SIPC brochure, by contacting SIPC by phone at (202) 371-8300 or by visiting the SIPC website at www.sipc.org.
Payment for Order Flow
Wall Street Access sends certain equity orders to exchanges, electronic communication networks, or broker-dealers during normal business hours and during extended trading sessions. Certain venues provide payments or charge access fees to Wall Street Access depending upon the characteristics of the order and any subsequent execution. The details of these payments and fees are available upon written request.
Wall Street Access receives compensation for directing listed options order flow to certain options exchanges. Compensation is generally in the form of a per-order cash payment. The details of these payments and fees are available upon written request.
Order Routing and Execution
Wall Street Access selects venues and makes order routing decisions based on the overall ability of each venue to provide our customers’ orders with quality executions. Our customers’ orders are routed directly to market centers for execution, rather than through a third-party intermediary. As well, we conduct regular and rigorous evaluations of execution quality that includes factors such as execution speed, execution price relative to the overall market, price improvement, liquidity enhancement, fill rates, and print protection. Disclosure of SEC required order execution information. SEC Regulation NMS Rule 606 (Disclosure of Order Routing Information) and SEC Regulation NMS 605 (Best Execution) requires Wall Street Access to prepare statistical reports on Wall Street Access’ order executions, routing and best execution. This information about Wall Street Access is publicly available at https://public.s3.com/rule606/wabr/ for SEC 606 reports and: https://public.s3.com/rule605/vndm/ for SEC 605 reports. For older reports visit: https://www.fisglobal.com/ptc/ A hardcopy will be furnished upon request. Rules 606(b)(1) and 606(b)(3), customer requests for information on order routing reports, are available on request by the customer in XML schema and PDF format.
Limit and Market Order Protection
Wall Street Access established information barrier processes between trading units such that different trading units will have no knowledge of orders held by other trading units. Under these circumstances, and in accordance with Finra Rule 5320, Wall Street Access will not provide order protection to unexecuted market or limit orders held in different trading units.
Not Held orders
When you send us an order on a “not held” basis you are giving the firm time and price discretion in seeking to obtain best execution for your order. A “not held” order is generally not offered price protection and the firm may trade for its own account at prices equal to, or better than those of “not held” orders. All purchases and sales will be consistent with us providing best execution of your orders.
Trading on a Net Basis
Wall Street Access may confirm trades to you on a net basis inclusive of any commissions, commission equivalent, mark-up or mark-down. The reported price may reflect an “average price” with the mark up or mark down included, which represent the compensation for services provided by our firm. The compensation received will be within the acceptable guidelines provided by FINRA.
Extended Hours Trading Risk Disclosure
Extended Hours Trading refers to Pre-Market Trading session and After-Hours Trading sessions that occur outside the standard trading session — 9:30 a.m. ET to 4:00 p.m. ET. Orders received by Wall Street Access outside of normal market hours are not eligible for pre-market or after-hours trading executions unless specifically requested by the customer. In accordance with FINRA and NASDAQ Rules, Wall Street Access is required to disclose the common risks associated with trading in extended sessions that you should be aware of:
Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.
Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular market hours.
Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours.
Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
Risk of Partial Executions. Orders placed during extended trading hours may be entered through a participating ECN or exchange, which may be linked to other ECNs or exchanges. Because you cannot add qualifiers to an order, such as AON or FOK, a round lot order may be filled in part by an odd lot or mixed lot order, leaving stock left over to buy or to sell. There is a risk that the remaining order may not be filled during the extended-hours session. An odd lot may not be represented in the displayed quote. This would occur in instances in which an order has an execution leaving an odd lot. There are no execution guaranties for an odd lot or the odd lot portion of a mixed lot portion of an order.
Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (“IIV”). For certain Derivative Securities Products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the Opening and Late Trading Sessions, an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.