Business Continuity Planning
Hamilton 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 you cannot contact us after a significant business disruption as you usually do at 212-306-5993, you should go to our website at www.hamiltonex.com If you cannot access us through either of those means, you can e-mail [email protected]
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 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.
Varying Disruptions
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 three 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 one day. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website www.hamiltonex.com 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.
AML CIP Disclosure
Customer Identification Program To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions, such as Hamilton, to obtain, verify and record information that identifies each individual or institution that establishes a customer relationship with such financial institutions. We deal generally with financial institutions that do not meet the definition of a customer. If a client, who does meet the definition of a customer, enters a relationship with Hamilton, which includes opening an account at Hamilton, we will request certain financial and legal information about such client, including such client’s legal name, tax identification number and address, and the identity of any individuals with any authority or control over such client. We also verify such information to the extent required as follows:
•Taking steps to check the information provided – to verify that the clients are who they say they are.
•Consult applicable governmental agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if anyone on any such list is attempting to open or maintain an account.
•Conduct, in certain instances, additional due diligence when accounts are opened for foreign persons, institutions or other clients.
The U.S. Department of the Treasury, U.S. Securities and Exchange Commission (the “SEC”) and FINRA rules already require clients to provide most of this information. If a client refuses to provide the information requested or a client’s identity cannot be verified, Hamilton may not be able to establish or maintain a business relationship with such client. If such client has already established a relationship with Hamilton, we may have to terminate such relationship. If a client establishes a relationship with Hamilton and refuses to provide this information, we may be required to report such refusal to appropriate governmental authorities. Pursuant to U.S. regulations issued under section 311 of the USA PATRIOT Act, 31 CFR 103.192, we are prohibited from opening or maintaining a correspondent account for, or on behalf of the “Specified Institutions” or Jurisdictions of Primary Money Laundering Concern (https://www.fincen.gov/resources/statutes-and-regulations/311-special-measures). The regulations also require us to notify you that your correspondent account with our financial institution may not be used to provide the Specified Institutions with access to our financial institution. If we become aware that the Specified Institutions are indirectly using the correspondent account you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including terminating your account.
Privacy Policy
Hamilton has a commitment to the protection of our client and counterparty privacy and confidentiality of client information and has in place systems and processes that isolate and protect our institutional customer’s proprietary and or confidential information from release to the general public. We do collect certain information from our customers in order to process their accounts and enact requested trades on their behalf. We do not release, resale or broadcast client information and our systems are set up to protect client confidential information. We will, however, release this information to federal, state and our DEA or SRO as required by law and statute. We may not be able to notify you of any such release, however, we will notify all of our counterparties if there is a resale of counterparty information to the public.
Order Routing (606)
Hamilton, an agency floor broker on the NYSE American options trading floor, considers all orders sent to the Firm as directed orders for the purposes of Rule 606 of SEC Regulation NMS.
Member Exchange(s)
Hamilton is a member of the NYSE American Options (AMEX) and FINRA
SIPC
Member of SIPC
Affiliations
Hamilton Executions LLC is under common control with Casey Securities LLC and FOG Equities LLC
