Business Continuity Statements

Compass Point Research & Trading, LLC has developed a Business Continuity Plan, which describes 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 cannot contact us as you usually do through your account executive, you should call our main office number 202-540-7300 or go to our web site at www.compasspointllc.com. If you cannot access us through either of those means, you should contact our clearing firm, StoneX (f/k/a INTL FCStone Financial, Inc.), at (800) 240-1438, for instructions on how they can provide prompt access to your funds and securities, other cash and security transfer transactions.

 

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, and allowing our customers to transact business. 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 backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical vendors, contractors, banks, and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

 

Our clearing firm, StoneX, backs up important accounts and trading records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that their objective is to quickly restore their own operations and be able to complete existing transactions and accept new transactions and payments. Your orders and requests for funds and securities could be delayed during the restoration period.

 

Varying Disruptions – Significant business disruptions can vary in their scope, such as the business district, the city, or the entire region where one or more of our offices are located. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to one or more of our offices we will transfer our operations to an appropriate site when needed and expect to recover and resume business within twenty-four hours. In a disruption affecting a larger area we will transfer our operations to a site outside of the affected area when needed and expect to recover and resume business within forty-eight hours. In either situation, we plan to continue in business, transferring operations to our clearing firm if necessary, and notify you through our web site www.compasspointllc.com on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will ensure our customers’ prompt access to their funds and securities.

 

For more information – If you have questions about our business continuity planning, you can contact us at:

1055 Thomas Jefferson Street, NW
Suite 303
Washington DC 20007
Phone: (202)-540-7300
Fax (202) 540-7311
info@compasspointllc.com

 

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Customer ID Procedures 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, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

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Electronic Communication Disclosure

Electronic communications from Compass Point Research & Trading, LLC (Compass Point) may contain information that is proprietary, privileged, confidential, and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is strictly prohibited. If you receive a message in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format.

Electronic communications from the firm are for informational purposes only. They are not intended as an offer or solicitation for the purchase or sale of any financial instrument or as an official confirmation of any transaction. Any market prices, data and other information are not warranted as to completeness or accuracy and are subject to change without notice. Comments or statements made therein by an individual do not necessarily reflect the views of the firm or its affiliates.

Although electronic communications and any attachments from Compass Point are believed to be free of viruses or other defects that might affect a computer system into which they may be received and opened, the firm cannot ensure that this is the case and it is the responsibility of the recipient to ensure that viruses, malware or other defects are blocked or neutralized. Compass Point shall have no responsibility for any loss or damage arising in any way from the use or receipt of its electronic communications.

Information may not be secure or timely when transmitted electronically. As such, the firm shall have no responsibility for the contents of any email or other electronic communication or for any delays, inaccuracies or omissions in the receipt of your instructions or in the transmission of orders or other information and disclaims all liability to the fullest extent permitted by applicable law for any loss or damage arising from any reliance on or use of electronic communications in any way. You may not transmit, nor is Compass Point obligated to accept, orders, instructions or identifying information regarding your account(s) via email. Action-oriented messages, transaction orders, fund transfer instructions or check stop payment instructions should not be transmitted via email. The firm is not responsible for carrying out such orders and/or instructions. An order or instruction is not considered active or received until it is acknowledged and accepted by the firm.

Please note that any electronic communication that is transmitted within or through Compass Point’s systems is subject to monitoring, review, retention, and external production.

Compass Point Research & Point, LLC is a member of FINRA/SIPC.

For disclosures in respect of messages prepared by Compass Point Sales and Trading personnel, please see Trading Disclosures below.

For disclosures relating to specific companies referenced in Compass Point research, please see the last pages of all Compass Point published research.

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Trading Disclosures

Compass Point Research & Trading, LLC (“Compass Point” or “the Firm”) is committed to providing best execution for all its customers. When Compass Point receives a customer order, it uses reasonable diligence to ascertain the best market for the subject security so that the resultant price to the customers is as favorable as possible under prevailing market conditions. The firm will refrain from conduct that could disadvantage or harm the execution of a customer order or engage in activity that will place its financial interests ahead of its customers.

Depending on the circumstances, Compass Point, while holding a customer order, may trade in the security for its own account either to:

  • Facilitate the order; *
  • Liquidate or cover an existing position established in connection with facilitating the order; * or
  • Create or modify a bona fide hedge of the risk acquired in facilitating the order.

* (or the order of one or more other customers)

Whenever the firm trades for its own account while holding a customer order, it will do so in compliance with applicable SEC and SRO rules that are meant to protect customer interests, e.g. FINRA Rule 5310 (Best Execution and Interpositioning) and FINRA Rule 5320 (Prohibition Against Trading Ahead of Customer Orders). Customers should be aware that trading activity related to the facilitation of their orders could affect the market for the subject security. Compass Point may work to limit the risk after a

DETERMINING WHERE TO ROUTE CLIENT ORDERS

Compass Point assesses the quality of the markets to which it routes order flow to obtain best execution on behalf of its clients. In this regard, the firm may, depending on several factors, including the security involved or the size of the order, execute the order with itself as principal or may route client orders to other market centers for execu­tion. Compass Point stands to share in 100 percent of whatever profits we generate by trading as principal against our customer orders. Several of the broker-dealer market makers and exchanges offer automated execution systems for reported securities as defined in SEC Rule 606 (Disclosure of Order Routing Information). Typically, the firm sends its small orders in reported securities to one of these automated trading centers for execution.

Orders sent to various OTC market makers in listed or OTC stocks may be exposed to certain exchanges and market centers for the purpose of obtaining price improvement. Orders sent to an exchange via an auto­mated routing and execution system have the opportunity to be executed at prices better than the National Best Bid or Offer, either pursuant to a computerized pricing algorithm (in the case of orders in a stock with a spread greater than $0.01) or order exposure features of such systems.

EXECUTION QUALITY AND ORDER ROUTING DISCLOSURE (SEC RULE 606)

The Securities and Exchange Commission (“SEC”) approved Rule 606 of Regulation NMS to improve public disclosure of order execution and routing information and to provide investors the right to certain information.

http://www.sec.gov/divisions/marketreg/disclosure.htm

RULE 606 – In accordance with SEC Rule 606, as amended April 30, 2019, the firm compiles and publishes a quarterly report regarding its routing of held, non-directed customer orders in national market system securities and listed options with a notional value of less than $50,000.00. This report can also be viewed on FINRA’s website: NMS Equity and Option Order Routing Reports (SEC Rule 606(a) Reports).

Customers may request a written copy of the report free of charge. In addition, customers may request the firm to furnish a report identifying the venue to which their orders in national market system securities and listed options were routed for execution in the six months prior to the request, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, resulting from such orders. Please contact your Compass Point Sales representative to request SEC Rule 606 order routing information.

Form CRS

Privacy Policy

Compass Point Research & Trading, LLC respects your right to privacy. We have always been committed to securing the confidentiality and security of information we collect about our customers. Nonpublic information about you will not be shared with third parties without your consent, except for the specified purposes described below. This notice describes the information we may gather from you and the circumstances under which we may share it. We are proud of our privacy practices and want our current and prospective clients to understand what information we collect and how we use it.

Why We Collect Your Information – We gather information about you and your accounts so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the products and services we offer and (iii) comply with the laws and regulations that govern the financial industry.

What Information We Collect – We may collect the following types of ‘nonpublic personal information’ about you:

  • Information about your identity, such as your name, address and tax identification number;
  • Information about your transactions with us;
  • Information we receive from you on applications, forms or through discussion.

Sources From Which We Obtain Your Information – We collect nonpublic personal information about Compass Point Research & Trading LLC clients such as you from the following sources:

  • Information we receive from you on applications, forms or through discussion;
  • Information we may obtain via the Internet;
  • Information we receive from our clearing firm or third-party vendor for authentication purposes.

What Information We Disclose – Your securities account is carried by our clearing firm pursuant to clearing agreements. We may disclose to them all the information we collect regarding your account. Our clearing firm is contractually obligated to keep the information that we provide them confidential and use the information only for the services required and as allowed by applicable law or regulation.

We may also disclose information to third parties to effect a transaction you request or authorize, for example, to a bank from which you wish to purchase a certificate of deposit.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law and noted above. Moreover, we will not release information about our customers or former customers, except as noted above 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 or regulation to release information to the recipient.

What are my rights to opt out of disclosure – In certain circumstances, the law allows you to “opt out” of our sharing nonpublic personal information about you with affiliated and nonaffiliated companies; that is, you may direct us not to make such disclosures. Currently, we do not share information about you with any affiliate or third party that triggers this “opt out”; therefore, there is no need to “opt out”. If in the future we desire to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to “opt out” of such disclosure.

Confidentiality And Security – We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized 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 your account is closed or becomes inactive.

Protecting Your Information

There are a number of steps you can take to protect your information, including 1) before you reveal any personally identifying information, find out how it will be used and whether it will be shared with others; 2) pay attention to your billing cycles and follow up with creditors if your bills don’t arrive on time; 3) guard your mail from theft; 4) deposit outgoing mail in post office collection boxes or at your local post office; and, 5) put passwords on your credit card, bank and phone accounts.

If you suspect that your personal information, including social security number or account information has been misappropriated to commit fraud or theft please contact: 1) your CPRT personal representative; 2) the fraud departments of each of the three major credit bureaus; 3) the creditors for any accounts that have been tampered with or opened fraudulently; and 4) your local police or the police in the community where the identify theft took place. You should also contact the Federal Trade Commission (FTC) at 1-877-IDTheft or at www.consumer.gov/idtheft

Please be advised that this privacy notice is subject to change. In the event that changes occur, you will be informed in accordance with applicable laws. A copy of this privacy notice may also be obtained by contacting our office.

Important Disclosures