Your Privacy is Protected
At HJ Sims, an important part of our commitment to you is our respect for your right to privacy. Protecting all the information we are either required to gather or which accumulates in the course of doing business with you is a cornerstone of our relationship with you. While the range of products and services we offer continues to expand and the technology we use continues to change, our commitment to maintaining standards and procedures with respect to security remains constant.
Collection of Information
The primary reason that we collect and maintain information is to more effectively administer our customer relationship with you. It allows us to identify, improve and develop products and services that we believe could be of benefit. It also permits us to provide efficient, accurate and responsive service to help protect you from unauthorized use of your information and to comply with regulatory and other legal requirements.
Various sources are used to collect information about you, including (i) information you provide to us at the time you establish a relationship, (ii) information provided in applications, forms or instructions completed by you, (iii) information about your transactions with us. In order to maintain the integrity of client information, we have procedures in place to update such information, as well as to delete it when appropriate. We encourage you to communicate such changes whenever necessary.
Disclosure of Information
HJ Sims, does not disclose any nonpublic, personal information (such as your name, address or tax identification number) about our clients or former clients to anyone, except as permitted or required by law. We maintain physical, electronic and procedural safeguards to protect such information and limit access to such information to those employees who require it in order to provide products or services to you.
We are also permitted to disclose nonpublic, personal information to unaffiliated outside parties who assist us with processing, marketing or servicing a financial product, transaction or service requested by you, administering such a transaction, product or service, and/or providing confirmations, statements, valuations or other records or information produced on our behalf.
HJ Sims has developed a Business Continuity Plan detailing 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 regarding our business continuity plan.
If after a significant business disruption you cannot contact us as you usually do, you should call our alternative numbers 800-457-1935, 888-457-1935, 800-300-9040 or go to our web site at hjsims.com. If you cannot access us through any of those means, you should contact our clearing firm, Pershing LLC, at 201-413-3635 for instructions on how they will assist you in processing trade-related transactions, cash disbursements and security transfers.
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, our clearing firm has advised us that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four hours. Your orders and requests for funds and securities could be delayed during this period.
Significant business disruptions can vary in their scope, such as only 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 a local site when needed and expect to recover and resume business within two hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within four hours. In either situation, we plan to continue in business and notify you through our web site at hjsims.com or our customer emergency numbers 800-457-1935, 888-457-1935 or 800-300-9040 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 (800) HJS-1935 or submit an inquiry online.
Disclosure of Payment for Order flow and Order Routing Information
The Securities and Exchange Commission (“SEC”) requires that all broker/dealers disclose their policies regarding the receipt of payment for order flow, the nature of their order routing policies for orders subject to payment for order flow and the degree to which these orders can receive price improvement.
Regulation NMS Rule 607 – Payment for Order Flow
Pursuant to SEC Rule 607, Herbert J. Sims (HJS) is required to disclose its payment for order flow practices. Order flow payment is compensation received as an incentive to direct (i) securities trades to exchanges that provide rebates to post certain orders and (ii) option trades to option market makers or option exchanges that provide rebates for certain option orders. HJS executes all its Equity trades with BNY Mellon’s Pershing Equity desk. Pershing is HJS’s custodian. HJS does not receive payment from BNY Mellon’s Pershing for directing order flow.
Regulation NMS Rule 606 – Order Routing Information
For additional information regarding the order routing practices and the venues to which your Held equity and Held and Not Held option orders were routed, you may view a quarterly Order Routing Disclosure pursuant to SEC 606(a) by visiting www.orderroutingdisclosure.com.
Enter Broker-Dealer’s Full Name: HERBERT J SIMS to access information.
Upon written request to Pershing, you may obtain the identity of the venue to which your Held equity and Held and Not Held option orders were routed for the six months prior to your request and the time of the transactions that may have resulted from such orders pursuant to SEC Rule 606(b)(1).