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Payment
for Order Flow
&
Routing of Customer Order
Disclosure Statement
Policy Regarding Receipt of Payment
for Order Flow
Presidential
Brokerage, In. ("PBI") assesses the quality of the markets to which
it routes order flow because meaningful opportunities for market improvement
may exist. Our primary objective is to obtain the best execution for
our clients, irrespective of any compensation factor.
Currently, in return for routing an order to a specific market or market
maker, we may receive financial compensation. Updated as of November
22, 2002, PBI does not receive financial compensation for directing
order flow.
Policy for Determining Where to Route Customer Orders
PBI
continually assesses the quality of the markets to which it routes order
flow in order to obtain the best execution of behalf of its clients.
Absent specific instruction from a client as to where to route an order,
depending on the security involved and/or the size of the order, PBI
may execute the order itself, with other broker/dealer market-makers,
or through other market facilities, several of which offer automated
execution services. PBI typically sends small orders through one of
the automated execution systems.
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PRESIDENTIAL
BROKERAGE, INC.
PRIVACY STATEMENT
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The
Securities and Exchange Commission has implemented Regulation S-P, which
relates to the privacy of consumer financial information. Regulation S-P
and the Gramm-Leach-Bliley Act limit investment companies, broker-dealers
and registered investment advisers in their disclosure of consumer's and
customer's nonpublic personal information. Regulation S-P also requires
that financial institutions provide privacy notices in various instances
and to adopt policies and procedures to protect the personal information
of its consumers and customers. This statement describes our firm's privacy
policy and how we handle your personal information. This policy applies
to former, current, and prospective customers.
Presidential
Brokerage, Inc., is Committed to Protecting Your Privacy
We respect every individual's right to privacy. We understand the importance
you place on the privacy and security of information that personally identifies
you or your account information.
Why and How We Collect Personal Information
We are required by guidelines of our industry, such as New
York Stock Exchange Rule #405, Know Your Customer, to obtain personal
information about you for the purpose of providing investment recommendations,
evaluating your financial needs, processing your requests and transactions,
and providing customer service. The personal information we collect about
you includes:
- Information we
receive from you to open an account or provide investment advice to
you. This information typically includes your home address, telephone
number and financial information.
- Information that
we access or generate to service your account, such as account statements
and securities holdings.
- Information that
we may receive from third parties with respect to your account, such
as accounts you may have at other financial institutions or trade confirmations
with other brokerage firms.
We
Protect the Confidentiality of Your Personal Information in the Following
Manner
- We
do not sell personal information to anyone.
- We disclose personal
information only as required by law or with your permission.
- We disclose or
report personal information in limited circumstances where we believe
in good faith that disclosure is required under law, to cooperate with
regulators or law enforcement authorities, or to protect our rights
or property.
- We use personal
information in ways that are compatible with the purposes for which
we originally requested it. For example, we will use the information
you give us to process your requests and transactions, to provide you
with additional information about products and services, or to evaluate
your financial needs. To do so, we may share personal information with
an agent or affiliate.
- We limit the collection
and use of personal information to what is necessary to administer our
business and to deliver services to you. This may include advising you
about our products or services.
When
We Share Your Personal Information With Our Affiliates
In order for us to
provide investment recommendations to you, we may disclose your personal
information in very limited instances which include:
- Disclosures to
companies as permitted by law, including those necessary to service
your account, such as providing account information to our fully disclosed
clearing firm and/or and custodians
- Disclosures to
companies that perform services on our behalf, such as mailings pertaining
to products and services.
Presidential
Brokerage, Inc., is a fully disclosed correspondent firm of First Clearing
Corp.(FCC), a division of First Union Corp. FCC conducts numerous functions
for Presidential Brokerage, Inc., including securities transactions, record
keeping, receipt of and disbursements of funds, generation and distribution
of account statements, and acts as custodian for all securities held in
street name. FCC maintains very strict privacy guidelines and your personal
information is protected in this relationship through a strict confidentiality
agreement.
How We Protect Your Personal Information That We Share
With Our Affiliates
When we share personal information with an agent or affiliate, we protect
that information with a confidentiality agreement. Companies that we hire
to provide support services or act as our agent must conform to our privacy
standards. Our internal policies prohibit employees who have access to
our customerÕs personal information from using or disclosing the information
except for the appropriate business use of Presidential Brokerage, Inc.
All employees are required to sign a confidentiality agreement that requires
them to protect your personal information.
Updating Your Personal Information
We will give you reasonable access to the information we have
about you. Most of this information is contained in account statements
that you receive and applications that you submit to obtain our products
and services. The accuracy of your personal information is important.
We encourage you to review this information and notify us of needed updates
and/or changes. Please call us at 800-230-1288.
MEMBER: NASD SIPC
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