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 alternate locations.  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 a couple hours and in the second scenario, its planned recovery time is expected to be within one week.

Wall Street Access intends to notify its customers by phone or by its website 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 on our website at or by requesting a written copy of the plan by mail.

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 Website address is
  • 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 Website noted above.

Customer Identification Program Notice

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.  This notice answers some questions about the Firm’s Customer Identification Program.

What types of information will I need to provide?

When you open an account, our firm is required to collect the following information:

– Name, date of birth, address

– Identification number:

• 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.

You may also need to show 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.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance.

What happens if I don’t provide the information requested or my identity can’t be verified?

Our firm may not be able to open an account or carry out transactions for you. If our firm has already opened an account for you, we may have to close it.

Securities Investor Protection Corporation (SIPC)

Wall Street Access is a member of 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

SEC Rule 607 Disclosure

Rule 607 of Regulation NMS requires broker-dealers to disclose, upon opening a new customer account and on an annual basis thereafter: (i) their policies regarding payment for order flow, including a statement as to whether any payment for order flow is received for routing customer orders and a detailed description of the nature of the compensation received; and (ii) their policies for determining, in the absence of specific customer instructions, where to route customer orders that are the subject of payment for order flow, including a description of the extent to which orders can be executed at prices superior to the National Best Bid / Offer (“NBBO”).

Certain venues offer cash credits or rebates for orders that provide liquidity to their books and charge explicit fees for orders that extract liquidity from their books. We route orders to exchanges that provide these programs and may be eligible for these benefits under the exchange rules. For any execution, customers may request that the venue on which their orders have been executed, and whether we received a rebate from such venue during the relevant time. Our routing decisions are based on a number of factors, including but not limited to price, liquidity, venue reliability, cost of execution, likelihood of execution and potential for price improvement. The Firm provides its practices in accordance with SEC Rule 607 to its customers through the Firm’s website, which is available at In addition, the Firm sends the Rule 607 disclosure to its customers in a yearly mailing and upon the opening of a new account.

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 and options brokers. Compensation is generally in the form of a per-order or per contract cash payment.  The details of these payments and fees are available upon written request. Orders may be routed and executed internally through our trading desk. In such instances, the firm stands to share in 100% of whatever profits it generates by trading as principal.

Additional information will be provided upon written request and certain order routing information including net payment and rebate information is available at

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 for SEC 606 reports and: for SEC 605 reports. For older reports visit: 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

FINRA Rule 5320 (Prohibition Against Trading Ahead of Customer Orders) generally provides that a broker-dealer handling a customer order in an equity security is prohibited from trading that security on the same side of the market for its own account at a price that would satisfy the customer order, unless the firm immediately executes the customer order up to the size of its own order at the same or better price. This rule automatically applies to all customer orders except for the following: Institutional Accounts: If a customer order is received from an “institutional account,” as defined in FINRA Rule 4512(c), the firm may trade for its own account at a price or prices that would satisfy the institutional customer order. Notwithstanding, an institutional customer may “opt in” to the Rule 5320 protections (i) with respect to any particular order by notifying the firm at the time of placing the order, and (ii) with respect to all orders for their account by providing written notice to: : Wall Street Access 100 Wall Street, 8th Floor, New York, NY 10005, Attn: Compliance or customers may call Compliance at (212) 709-9400.

Large Orders: If a customer order is received and the order represents 10,000 shares or more and $100,000 in value or greater (a “large order”), the firm may trade for its own account at a price or prices that would satisfy the customer order. Notwithstanding, any customer entering a large order may “opt in” to the Rule 5320 protections (i) with respect to any particular large order, by notifying the firm at the time of placing the order, and (ii) with respect to all large orders for their account, by providing written notice to: Wall Street Access 100 Wall Street, 8th Floor, New York, NY 10005, Attn: Compliance or customers may call Compliance at (212) 709-9400.

“Not Held” Orders: When customers place “not held” orders, they are giving time and price discretion to the firm so that the Firm may exercise its professional judgment in an effort to obtain best execution for the customer. In the process of executing the “not held” order, the firm may trade in the security for its own account prior to completion of the customer order and at the same or a better price than the customer receives.

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.

Order Execution – FINRA Rule 5270

FINRA Rule 5270 (Front Running of Block Transactions) prohibits FINRA member broker-dealers from executing orders to buy or sell certain securities or related financial instruments when the member has material, non-public information concerning an imminent block transaction in those securities. The rule permits certain exceptions to this prohibition, including transactions that are undertaken to fulfill or facilitate the execution of a customer block order. The firm may rely on the rule’s exceptions while effecting block orders for its customers. In connection with the handling of block orders, the firm may engage in hedging, offsetting, liquidating, facilitating, or positioning transactions (“risk-mitigating transactions”) that may occur at the same time or in advance of customer orders, and these activities may have an impact on market prices.

Unless a customer informs the firm otherwise in writing to “opt out”, the firm will conclude that it may engage in risk-mitigating transactions in connection with such orders and that customers have given their consent to the firm to handle block transactions as described above. A customer may choose to opt out by providing written notice to: Wall Street Access 100 Wall Street, 8th Floor, New York, NY 10005, Attn: Compliance or customers may call Compliance at (212) 709-9400.

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.

If a customer no longer wishes to have their orders handled on a “net basis,” the customer can inform their representative or call Compliance at (212) 709-9400. If a customer does not notify the firm that they don’t want their orders or a specific order to be executed on a net basis, the firm will continue to accept net orders when agreed upon at the time orders are placed.

Extended Hours Trading Risk Disclosure

You should consider the following points before engaging in extended hours trading. “Extended hours trading” means trading outside of “regular trading hours.” “Regular trading hours” generally means the time between 9:30 a.m. and 4:00 p.m. Eastern Standard Time.

•   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 trading 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 trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading 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 trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading 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 trading hours. Similarly, important financial information is frequently announced outside of regular trading 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.

Option Disclosure Document

For customers who trade options or who receive options related sales literature, the various Exchanges require that those customers be provided a current copy of the Options Disclosure Document (ODD) issued by the OCC as well as any supplements. The most recent ODD including supplements may be obtained at the following web link: Copies of the complete Option Disclosure Document are available upon request. You may contact the compliance department at (212) 709-9400.

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. If you have questions about our privacy policy, please contact us via email at or call WSA customer service at (800) 758-5195.

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 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.

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 or call WSA customer service at 1-800-758-5195.

Complaint Reporting

If you have a complaint, contact our customer service department at (800) 758-5195, email us at, or write our compliance department: Wall Street Access, Attn: Compliance Department, 100 Wall Street, 8th Floor, New York, NY 10005.