Regulatory Disclosures
 
StormHarbour Securities LLP (London)
 
StormHarbour Securities LLP is authorised and regulated by the Financial Conduct Authority.
Our Firm Reference Number on the Financial Services Register is 503459.
 
To access the FCA Register of Authorised Firms and Approved Persons, please click: "Register".
 
To view Pillar 3 Disclosure, please click: "Pillar 3".
 
To view our Order Execution Policy, please click: “Order Execution Policy
 
To view the Remuneration Code Disclosures, please click: “Remuneration Code Disclosure
 
Notice to Australian clients: "Notice".
 
 
 
 
StormHarbour Securities LP (New York)
 

The following information is provided by StormHarbour Securities LP (“StormHarbour”, the "Firm") as required by US regulations and the rules of Financial Industry Regulatory Authority (“FINRA”) and Municipal Securities Rulemaking Board.

Anti-Money Laundering Compliance and Customer Identification Programs

Pursuant to the USA Patriot Act (“the Act”) StormHarbour has implemented an Anti-Money Laundering Compliance Program. To meet requirements set forth under the Act and by the Firm’s Customer Identification Program, You will be asked to provide information about your entity, including, but not limited to; names of individuals or entities having significant ownership interests in or control over your entity, principal operating officers, authorized traders, IRS Tax ID Number,  organizational agreements, confirmation that you are exercising independent investment decision making when entering into transactions with StormHarbour, confirmation of assets under management, and financial condition.

Privacy Notice

StormHarbour is committed to protecting your privacy.  The Firm may hold nonpublic information provided by you during the new account onboarding process and will maintain trade records of all transactions you enter into with StormHarbour.  This information will be shared with our clearing agent in order to settle your transactions.  The Firm does not otherwise disclose or share nonpublic information obtained from you or from former customers with anyone, except as authorized by you, required by law or as a result of a regulatory request.

Information Security

StormHarbour and its employees treat the nonpublic information collected from you as confidential.  The Firm has implemented security policies and protocols, compliant with US regulations, to safeguard information stored digitally and documents held at our offices. Employees are trained in and monitored to ensure they adhere to “best practices” security procedures whenever they are in possession of or discuss nonpublic information.

Business Continuity Plan

The Firm will make every effort to continue to conduct business and meet our obligations to counterparties in the event of a significant business disruption.  If the Firm is forced by circumstances beyond our control to temporarily halt business, the Firm’s senior managers will immediately initiate its Business Continuity Plan (“BCP”). Actions taken will be made known to you as soon as possible. The BCP is available upon request.   A brief description of the BCP is posted at www.stormharbour.com.

Review of Customer Complaints

All complaints should be addressed in writing to the Firm’s Compliance Department at the address shown above. All customer complaints will be reviewed upon receipt.  

Statement of Financial Condition 
                                       

StormHarbour’s most recent, audited Statement of Financial Condition is available upon request to the Compliance Department, at the address shown above.

Securities Investor Protection Corporation (“SIPC”)        
 

StormHarbour is a member of SIPC. Information about the SIPC and SIPC coverage, including how to obtain a copy of the SIPC Brochure, is available at the SIPC’s website: http://sipc.org or by calling 202-371-8300.

FINRA Public Disclosure and Hotline Number  
                                                          

StormHarbour is a member of FINRA. FINRA sponsors the BrokerCheck databank that is designed to give investors information about member firms (StormHarbour’s CRD# is 35997) and the professional background and conduct of FINRA registered employees. BrokerCheck and an investor brochure describing the program are accessible at FINRA’s website: www.finra.org.
The FINRA BrokerCheck Hotline Number is 800-662-2739.

 

This notice is provided for information purposes only. If you have any questions about disclosures made in this notice, please contact StormHarbour’s Compliance Department at the address above. The Firm’s main telephone number is 212-905-2500.                                   

April 2016

 

 

Business Continuity Planning Disclosure

StormHarbour Securities LP (“StormHarbour”) has developed a Business Continuity Plan (“BCP”) outlining 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 BCP.

Contacting Us – If after a significant business disruption (“SBD”), you cannot contact us as you usually do, you should call our alternative number at +44 20 7355 5750 or go to our Web site at www.stormharbour.com.  If you cannot access us through either of those means, you should contact our clearing firm, RBC Correspondent Services (“RBC”) at 612-371-2862 for instructions on how they may provide prompt access to funds and securities, execute orders and process other trade-related, cash, and security transfer transactions for you.

Our BCP – We plan to recover and quickly resume business operations after a SBD. Our response will include steps to safeguard our employees and property, make a financial and operational assessment, protect the Firm’s books and records, and allow our customers to transact business.  In short, our business continuity plan is designed to permit our Firm to resume operations as quickly as possible, considering the scope and severity of the SBD.
Our BCP addresses:  data backup and recovery;  mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location for employees; working with critical service providers; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

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 RBC that their objective is to restore operations and be able to complete existing transactions and accept new transactions and payments within four hours to accommodate switching of data processing and voice communications as well as relocation of associates to alternate facilities.  RBC archives our settlement records in a geographically separate area, remote from its primary location.  Any requests for funds and securities could be delayed during this period.

Varying Disruptions – SBDs can vary in their scope, such as disruptions affecting only our Firm, a single building housing one of  our  office, the business district where our main or branch office are located, the city where we are located, or the whole region.  Within each of these areas, the severity of the SBD can also vary from minimal to severe.  In a SBD affecting only our Firm, our main or branch office, or a building housing our main or branch office, we will transfer our operations to an alternate site when needed and expect to recover and resume business within the same business day.  In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and aim to resume business by the next business day.  In either situation, we plan to continue our business; relying on RBC for certain operations if necessary.  We will notify you of our recovery status on our Web site and by electronic communications and/or telephone.

You may contact StormHarbour by calling our emergency number +44 20 7355 5750.  This is the number of StormHarbour Securities LLP, our London affiliate.
 
If the SBD is so severe that it prevents us from remaining in business, we will work to ensure you prompt access to your funds and securities.

For more information – If you have questions about our BCP, please contact StormHarbour’s Compliance Department at 212-905-2500 or view our website at www.stormharbour.com.

 

 

Notice to Canadian Institutional Investors

Re: Reliance on the International Dealer Exemption and Notification to Permitted Clients pursuant to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (“NI 31-103”)
            Please be advised that StormHarbour Securities LP (the “Firm) is relying on the International Dealer Exemption in Canada pursuant to NI 31-103. Please note that:

i) The Firm is not registered as a dealer in any Canadian province or territory to make the trade;

ii) The jurisdiction of the Firm’s head office or principal place of business is in New York, United States;

iii) All or substantially all of the Firm’s assets may be situated outside of Canada;

iv) There may be difficulty enforcing legal rights against the Firm because of the above; and

v) 152928 Canada Inc., an affiliate of Stikeman Elliot LLP, is the agent for service of process of the Firm in British Columbia, Alberta, Ontario, and Quebec.

 

 

 

StormHarbour Securities (Hong Kong) Ltd.

NOTICE TO AUSTRALIAN CLIENTS

StormHarbour Securities Hong Kong Limited (“StormHarbour”) has made the necessary lodgements with the Australian Securities and Investments Commission for an exemption under Class Order 03/1103, as amended, from the requirement to hold an Australian financial services licence under the Corporations Act 2001 of Australia (“the Act”) in respect of the financial services provided to Australian wholesale clients.

In order to fulfill the notice requirements of Class Order 03/1103, as amended, StormHarbour is required to make the following disclosures to all wholesale clients in Australia to whom it will provide financial services in the future:

 
 

• StormHarbour is exempt from the requirement to hold an Australian financial services licence under the Act in respect of the financial services it provides to Australian wholesale clients; and

• StormHarbour is authorised and regulated by the Securities and Futures Commission of Hong Kong under Hong Kong laws, which differ from Australian laws.


We have classified you as a wholesale client for the purposes of Section 761G of the Act. If you disagree with your classification as a wholesale client please contact the Compliance Officer of StormHarbour.