Custom Identification Program Notice / Anti Money Laundering 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 Heflin & Company, LLC’s (“Heflin”) Customer Identification Program.

What types of information will I need to provide?

When you open an account, Heflin is required to collect information such as the following from you:
  • Your name
  • Date of Birth
  • Address
  • Identification number
  • U.S. Citizen: taxpayer identification number (social security number or employer identification number). You may also need to show your driver’s license or other identifying documents.
  • 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.
  • 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 trust agreement.
  • U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience, investment objectives, and risk tolerance.

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

Heflin may not be able to open an account or carry out transactions for you.

Payment For Order Flow Disclosure

Pursuant to SEC Rule 11Ac1-3, Heflin & Company, LLC is required to disclose to its customers its payment for order flow practices annually.

Heflin does not receive payment for order flow. Heflin & Co. LLC always seeks to obtain the best execution of your orders.

Business Continuity Plan

Heflin & Company, LLC has developed a Business Continuity Plan on 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 at our Los Angeles office (310) 335-9705, you should call our back up office in Los Angeles (310) 383-6602 or our North Carolina office (919) 610-0039. Trading will resume at one of our off site offices. If you cannot access us through either of those means, you should contact our clearing firm, Pershing LLC, at (201) 413-3635 for instructions on how it may process trade-related transactions, access to funds and securities (including disbursements and/or transfers) for you.

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 back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank 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, Pershing LLC, backs up our important 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 its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. Your orders and requests for funds and securities could be delayed during this period. However, due to the nature of our business, we have deployed our trading systems to handle orders via BLOOMBERG SEOMS. All orders are DVP.

Varying Disruptions – Significant business disruptions can vary in their scope, such as those only limited to our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to one of our 2 local remote sites if needed. We expect to recover and resume business within hours for we have set up redundant offices both locally and out of state that are fully functional. In a disruption affecting our business district, city, or region, we will transfer our operations to our North Carolina office and they will be able to resume business immediately. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site at www.heflinco.com, e-mail or our customer emergency number, (310) 335-9705 on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at (310) 335-9705 or info@helfinco.com.

Personal Privacy and Certain Information Sharing
This Privacy Policy summarizes Heflin & Company, LLC’s (“Heflin”) policies regarding the treatment of our customer’s nonpublic personal information. At Heflin, we appreciate the trust that clients place in us and we recognize the importance of protecting the confidentiality of nonpublic personal information that we have in our possession. The information is used to ensure accuracy in record keeping and to carry out requested transactions. Keeping this information secure is a top priority for Heflin and in keeping with recently adopted regulations.  Heflin & Co., LLC's Non-Public Personal information is only shared as allowed or required by law.
1.) This Privacy Policy applies to customers whose accounts are or were maintained by Heflin. We will provide our Privacy Policy to clients when they open a new account and annually thereafter. If we change this Privacy Policy, you will be notified in advance. We reserve the right to change these policies and practices at any time. Should changes be made to our existing policy, a revised Privacy Policy will be provided to you that incorporates these changes.

2.) The information we receive about you can be received in any manner, but it is usually obtained by telephone or by written communication. We obtain this non-public information about our clients from the following sources:

  • Information we have received directly from you as part of the account opening process (such as name, address, social security number, annual income, net worth, and investment objectives) or as a result of other requested services.
  • Information about client’s transactions effected through Heflin, specifically securities transactions. This information allows us to generate confirmations, statements and other required reports on behalf of our clients.

3.) The non-public personal information that is obtained is safeguarded in accordance with our internal policies and procedures. These policies permit only those employees who need to know the information in order to perform their duties to have access to customer’s non-public personal information. We maintain physical, electronic and procedural safeguards designed to comply with federal standards to guard client’s non-public personal information.

4.) Heflin does not have sharing arrangements with any affiliated company. We do not share information on current or former customers. We will not disclose your non-public personal information to non-affiliated third parties as we strive to protect the confidentiality, security, and integrity of your personal information.

5.) We will continue to adhere to the policies and procedures described in this Privacy Notice with respect to information that we have acquired about you even if we no longer provide services to you.

FINRA Public Disclosure Information

FINRA Conduct Rule 226, requires the following information be provided to you: (1) The FINRA Regulation, Inc. Public Disclosure Program hotline number is 1-800-289-9999; (2) The FINRA Website address is www.FINRA.org, and (3) The FINRA has a brochure available describing the public disclosure program.

Rule 606 (Report on Routing of Customer Orders) (This was former SEC Rule 11Ac1-6) Pursuant to SEC Rule 606, Heflin & Co., LLC quarterly order routing report(s) can be located at: www.heflinco.com Heflin & Co., LLC will also provide you with a copy of this report without charge. Please contact Heflin & Co., LLC if you want a copy sent to you.

Customers can request Heflin & Co., LLC to disclose the identity of the venue to which the customer's orders 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, that resulted from such orders.