Disclosures
Business Continuity Plan
Contact Information for Customer Complaints
Privacy
Anti-Money Laundering Policies & Customer Identification Program
To help the US government fight the funding of terrorism and money laundering activities, Federal law requires all US financial institutions to obtain, verify and record information that identifies each individual or institution that opens an account or establishes a customer relationship with The Riderwood Group Inc.
What this means: If you enter into a new customer relationship with the firm and you are an individual, the Firm will ask for your names, address, date of birth (if applicable), and other identification information which may be appropriate given your particular circumstances. This information will be used to verify your identity. As appropriate, the Firm may, in its discretion, ask for additional documentation or information. The firm also has standards when opening an account or establishing for an institutional entity and shall require information and documentation such as but not limited to:
- Requesting certain information from you, such as copies of your identification documentation, the legal name of financial institution conducting trades and tax identification number, location and designation of persons with trading authority.
- Taking steps to check the information provided - to verify that institutions are who they say they are.
- Consulting applicable governmental agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if someone on any such list is attempting to open or maintain an account.
- Conducting in certain instances, additional due diligence when accounts are opened for foreign persons or institutions, and other certain clients.
The US Department of the Treasury, Securities and Exchange Commission, and FINRA rules already required you to provide most of this information.
What happens if I don't provide the information requested or my identity can't be verified?
The firm may not be able to open an account or carry out transactions for you. If the firm has already opened an account for you, we may have to close it. If you open the account and refuse to provide this information, we may be required to report this action to appropriate governmental authorities.
Summary & Disclosure of BCP Planning
Date: July 11, 2008
We have prepared, and always maintain a current Business Continuity Plan ("BCP") in compliance with FINRA Rule 3510. This document outlines our plans to continue business and meet our existing obligations to customers in the event of a Significant Business Disruption ("SBD"). Our BCP is summarized below:
Our firm's policy is to respond to a SBD by safeguarding employees' lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm's books and records, and allowing our customers to transact business. We will make every reasonable effort to meet our obligations to customers at all times. We have in place a business continuity plan that outlines essential parts of our firm's business and in detail discusses:
- Data back-up and recovery (hard copy and electronic);
- All mission critical systems;
- Financial and operational assessments;
- Alternate communications between customers and the firm;
- Alternate communications between the firm and its employees;
- Alternate physical location of employees;
- Critical business constituents, banks, and counter-party impact;
- Regulatory reporting;
- Communications with regulators; and
- How the firm shall assure customers' prompt access to their funds and securities (if applicable) in the event that the member determines that it is unable to continue its business.
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm's ability to communicate and do business, such as a fire in our building or other localized emergency affecting our offices. Should our firm experience an internal SBD, the firm has in place alternate work locations complete with an infrastructure that would allow the firm to resume operations quickly, generally within two days. During the time that the firm may not be in operation, the firm provides the clearing firm's phone number for transactions and any other required client activity (trading, books and records, etc). Please contact NFS at 617-563-5977 or www.nationalfinancial.com
External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm. We have taken pains to make a business arrangement with a clearing firm that has backup facilities in many areas. Because our clearing firm has these locations that are geographically distant from our firm, the clearing firm or a portion thereof would be geographically distant from a large scale external SBD. Our clients already have contact information with regard to our clearing firm and are encouraged in times of business disruption to contact the clearing firm directly for assistance. In the event of a large scale disaster, the firm anticipates that it would generally be able to resume operations within 5 business days but anticipates that the clearing firm would be able to handle any customer needs within 2 business days.
In the event that we determine we are unable to continue the normal conduct of our business, due to any of the scenarios described above or any other circumstances, we will enact our BCP in order to assure customers prompt access to their funds and securities. Our BCP outlines the back-up facilities and arrangements that will be utilized in these circumstances. Briefly, the firm will work to restore its data and communications as outlined above and the clients may deal with the clearing firm immediately to provide trading and access to their securities. During the recovery period, the clearing firm will be able to handle all facets of the firm's customer related business.
We will make every reasonable effort to continue the conduct of business during any SBD, employing the use of our BCP. We plan to continue the conduct of business during any SBD unless circumstances prohibit us from doing so. If, for any reason, at any time, we are forced by circumstances outside our direct control to discontinue business, we will immediately determine our planned recovery time and communicate those plans to all concerned parties. Our BCP is subject to modification, update, and improvement at any time so that we may constantly assure ourselves, our customers, and any other concerned party of our readiness to confront a SBD.
Contact Information for Customer Complaints
Inquiries regarding trading inaccuracies or customer complaints should be forwarded to the firm's Chief Compliance Officer, Mitch Fillet at 410-825-5445 or via email at mfillet@riderwood.com or via US mail to our firm's main office or located at 1107 Kenilworth Drive, Baltimore, MD 21204.
Pursuant to Regulation S-P, the firm provides the following disclosure in relation to its use and protection of customer information. Our client's information remains secure with The Riderwood Group Inc. We do not share clients' information with third parties, other than to process transactions and service accounts and, in limited situations, where are required by law to do so. The firm is committed to providing our clients with the superior services and confidentiality they deserve. Consequently, we want to remind you of our Privacy Policy. We welcome your inquiries or suggestions and would be pleased to provide any additional information as required.
Privacy Policy
We may collect nonpublic information about clients and counterparties from various sources, which include the following:
- Information we receive on applications and other forms;
- Information about your financial transactions with us or others; and
- Information we receive from a consumer-reporting agency.
We may disclose any nonpublic information about customers to nonaffiliated third parties, as appropriate to conduct our services or as permitted by law. However, we reserve the right to disclose nonpublic personal information about customers collected as described above to our affiliated companies should we have any. Customers have the right to prevent the transfer of nonpublic, information to any non-affiliated third party or our affiliated companies before this information is disclosed to that third party. You can opt out by contacting our Compliance Department at the telephone number listed above. Upon receipt of your notice to opt out, your choice will continue in effect until revoked by you.
We restrict access to your information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. If you decide to cease your relationship with us or become an inactive customer, we will adhere to the privacy policy and practices as described in this notice.