In addition to the disclosures listed here, Canaccord Genuity Inc. maintains the following policies and makes the following disclosures.
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ANTI-MONEY LAUNDERING (CUSTOMER IDENTIFICATION PROGRAM NOTICE) (Customers of Canaccord Genuity Inc.)
Important Information You Need to Know About Opening A New Account
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 Canaccord Genuity’s Customer Identification Program.
What types of information will I need to provide?
When you open an account, Canaccord Genuity is required to collect information such as the following from you:
- Your name
- Date of birth
- Address
- Identification number
- US Citizen: taxpayer identification number (social security number or employer identification number)
- Non-US 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.
US 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?
Canaccord Genuity may not be able to open an account or carry out transactions for you. If we have already opened an account for you, we may have to close it.
We thank you for your patience and hope that you will support the financial industry's efforts to deny terrorists and money launderers access to the financial services industry.
© 2007. FINRA.
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BUSINESS CONTINUITY PLAN NOTICE
Canaccord Genuity is committed to providing a consistently high level of service to its clients. Certain events beyond the control of the firm could impact our ability to meet this goal. These events, or significant business disruptions, may include temporary inability to access facilities due to storms or local or regional power outages; natural disasters such as fire, flood, or hurricane; or intentional malicious attacks on facilities, systems, or personnel. In accordance with NASD Rules 3510 and 3520, NYSE Rule 446, and IIROC By-Law 17.19, Canaccord Genuity has developed and maintains a Business Continuity Plan (BCP) to address the impact of potential significant business disruptions. The BCP has been reasonably designed to enable Canaccord Genuity to provide for continued operations of critical functions to meet its obligations to customers.
Canaccord Genuity has designated a senior executive in charge of its business continuity program who is responsible for conducting an annual review of the plan. Named business continuity representatives are responsible for maintaining the plan to reflect any material changes to the firm's operations, structure, business, or locations. Additionally, the business continuity representatives are called upon to lead the resumption of operations should a significant business disruption occur.
The Canaccord Genuity’s BCP assesses the financial and operational risks of varying degrees of significant business disruptions, including building, citywide, and regional events. It identifies plans to protect and restore critical business processes, records, data, systems, and facilities. Depending on the nature of the disruption, our goal is to restore the most critical functions within a matter of hours, while less critical functions would be restored within several days. For security reasons, the specific details of our business resumption plan are not disclosed in this notice. However, Canaccord Genuity would like its clients to know that our BCP provides for a wide range of business continuance mechanisms, such as power generators, redundant components, systems, and communication technologies, and the implementation of alternate work and computing facilities.
The BCP addresses methods for communicating to customers, employees, counter-parties and other constituents in the event of a disruption, as well as ongoing communication with and reporting to regulators. Finally, in the event that a serious disaster forces Canaccord Genuity to discontinue operations, the plan addresses the mechanisms to provide customers with prompt access to their funds.
Canaccord Genuity’s BCP is subject to periodic review and modification. Should material changes to the plan occur, this notice will be updated accordingly. Customers may request more information regarding the Canaccord Genuity’s BCP by contacting bcp@canaccordgenuity.com.
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PRIVACY POLICY (Customers of Canaccord Genuity Inc.)
As a Canaccord Genuity client, you have entrusted to us your assets and your personal and financial data. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interest. Because your personal and financial information is private, we hold ourselves to the highest standards in its safekeeping and use.
We may collect non-public personal information about you from the following sources:
- Information we receive from you on account applications or other forms, such as your name, address, telephone number, social security number/social insurance number, income, assets, and investment objectives;
- Information about your transactions with us, our affiliates, or others, such as your account numbers and balances, investment activity, and other transaction information; and
- Information from employers that administer employee benefits programs through us.
We have adopted polices and procedures that are reasonably designed to ensure the security and confidentiality of customer information which includes consumer report information. In addition, these policies and procedures are designed to prevent unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer.
We use the information described above when administering your account. We may disclose non-public personal information in order to provide a service or complete a transaction that you request or authorize, or as otherwise required or permitted by the laws and industry standards that apply to us (i.e. anti-money laundering, regulatory requests). We may also disclose nonpublic personal information within our family of affiliated companies in order to inform you of other financial products and services that we offer.
We restrict access to non-public personal information about you to our employees who need to access the information to provide products and services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. Confidential customer information is destroyed or shredded prior to disposal.
Our privacy policies and procedures will continue to apply to your information even if your account is no longer active.
For your protection, we recommend that you do not provide your account information to anyone. If you become aware of any suspicious activity relating to your account, please contact us immediately.
You may receive notices of changes to our privacy policies and procedures or periodic updates of this notice, as required by law.
At Canaccord Genuity, we are proud of the trust and confidence we have earned from you. We will continue to earn that trust and confidence by keeping your non-public personal information secure and confidential.
In the United States, please contact Canaccord Genuity Inc. at 1.800.225.6201 or 1.617.317.3900 or in writing to Canaccord Genuity Inc., 99 High Street, Suite 1200, Boston, MA, 02110.
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SEC REQUIRED DISCLOSURE OF ORDER EXECUTION AND ROUTING INFORMATION
Canaccord Genuity trades National Market System Securities as a market maker in the Over-the-Counter market. Pursuant to Rule 605 adopted by the Securities and Exchange Commission, Canaccord Genuity is presenting certain information with respect to orders executed during the preceding month. You can obtain this information by accessing the following links: http://www.tta.thomson.com/msi/public1_5.html
(http://www.tagaudit.com/rule5.asp?user=adam for data prior to October 2007)
Pursuant to Rule 606 adopted by the Securities and Exchange Commission, Canaccord Genuity is presenting certain information with respect to orders executed during the preceding quarter. You can obtain this information by accessing the following links: http://www.tta.thomson.com/reports/ (http://www.tagaudit.com/rule6.asp?user=adam for data prior to October 2007) or quarterly reports are available upon request.
Please note that the vast majority of Canaccord Genuity’s customer trading activity is institutional in nature. Due to the size and trading strategies employed by these customers, most institutional orders are not subject to or relevant for Rule 605 or 606 reporting.
The SEC requires that the disclosure of a market center's order execution information be made available in an electronic data file, standard, pipe delimited, ASCII format, and compressed using standard Zip compression.
To effectively download and open Canaccord Genuity’s order execution information, installation of a Zip utility program such as WinZip (www.winzip.com) is required.
For an explanation of how to read these data, please refer to the SEC instructions for data presentation found in "Downloadable File Structure and Naming Conventions" on the www.tta.thomson.com or www.tagaudit.com website.
If you have any questions regarding this information, please contact us at disclosures@canaccordgenuity.com.
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SEC SHORT SALE ORDER AMENDMENT OF SEPTEMBER 21, 2008
Pursuant to the SEC Amendment to Emergency Order Pursuant to Section 12(k)(2) of the Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments dated September 21, 2008 (the "Order"), market makers may not knowingly effect a short sale as part of bona fide market making and hedging activity related directly to bona fide market making in a derivative security based on a Covered Security, if the customer's or counterparty's transaction will result in the customer or counterparty establishing or increasing an economic net short position (i.e., through actual positions, derivatives, or otherwise) in the issued share capital of a firm covered by the Order.
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