BUSINESS CONTINUITY PLAN
American Independent Securities Group, LLC (AISG, 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.
Contact Us: If after a significant business disruption you cannot contact us as you usually do at 664 S RIvershore Lane, Suite 150, Eagle, Idaho 83616, (208) 489-3131 or toll-free (866) 485-4635 you should use our alternative number, (208) 489-3123. If you cannot access us through either of those means, you should contact our clearing firm, RBC Clearing & Custody at (800) 949-0242 for instructions on how they may assist you in providing prompt access to your funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.
Our Business Continuity Plan: We plan to quickly recover and resume business operations after a significant business disruption (SBD) 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 (BCP) 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 counterparty 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, RBC Correspondent Services, 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 two (2) hours. Your orders and requests for funds and securities could be delayed during this period.
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 two (2) hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through local media or our customer emergency number, (208) 489-3123, 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 664 S Rivershore Lane, Suite 150, Eagle, Idaho 83616, (208) 489-3131 or toll-free (866) 485-4635.
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Municipal Securities Rulemaking Board
Municipal Securities can provide additional opportunities (and risks) for your portfolio. Transactions in Municipal Securities are regulated by the Municipal Securities Rulemaking Board. As with all investments, clients should understand the nature of the investment. An investor brochure is available on the MSRB website at www.MSRB.org that describes the protection that may be provided by the MSRB rules and how to file a complaint with an appropriate regulatory authority.
FINRA Anti-Money Laundering Disclosure
Important Information About Procedures for Opening a New Account: To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means to you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.
In the event you have a complaint with your Registered Representative, or with our firm, please direct the written complaint to: American Independent Securities Group, LLC, Attn: Compliance, 664 S Rivershore Lane, Suite 150, Eagle, Idaho 83616.
Payment for Order Flow
Unless otherwise instructed, your brokerage firm and/or its clearing agent routes equity orders taking into consideration, among other factors, the quality and speed of execution, as well as the credits and cash payments receivable from any exchange, other broker dealers and other market center. Whenever possible, your brokerage firm and/or its clearing agent will also attempt to obtain the execution regardless of any compensation your brokerage firm may receive. Your brokerage firm and/or its clearing agent may use the compensation received to help keep costs competitive and provide clients with quality execution services. The nature and source of payments and/or credits received in connection with a specific transaction will be furnished upon written request.
Notice of Availability of Order Routing Information – RBC Clearing & Custody prepares quarterly reports describing its order routing practices for non-directed orders routed to a particular venue for execution. These reports are publicly available at http://external.s3.com/rule606/rbcwm/correspondentsvcs/. RBC Clearing & Custody will furnish a printed copy of the quarterly report upon written request. In addition, RBC Clearing & Custody will provide on request more detailed information relating to the routing of any order in the six months prior to the request.
Investing in securities involves risks, and there is always the potential of losing money when you invest in securities. You should review any planned financial transactions that may have tax or legal implications with your personal tax or legal advisor.
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Order Routing/ Best Execution
RBC Clearing & Custody Services Best Execution Committee
The SEC has directed that all brokers have a duty to regularly and rigorously review their order routing decisions to ensure that client orders are routed to destinations where they are likely to receive “best execution.” Factors that are to be considered in such reviews include overall market quality, including the opportunity for an order to receive price improvement, speed of execution, order size, trading characteristics of a particular security, availability of accurate information affecting choices as to the most favorable market, availability of economic access to the various market centers and the cost and difficulty associated with achieving an execution in a particular market center.
The RBC C&C Best Execution Committee (“the Committee”) is comprised of senior management from RBC C&C Operations and finance. The Committee meets monthly to review statistics and other information pertaining to the execution quality provided by RBC C&C’ order routing destinations as well as competing venues. This review is mandated by RBC C&C’ written supervisory procedures and utilizes execution statistics required to be published by market centers pursuant to SEC Rule 605 and Rule 606, as provided to RBC C&C by S3 Matching Technologies, LP (“S3”). In addition to reviewing statistics and the other factors discussed above, the Committee also reviews order routing processes and technology, and makes suggestions to improve or replace those in place.
Obligations of Correspondents
FINRA recognizes that many firms, specifically those utilizing the services of a clearing firm for the execution of its orders, may never execute a customer order. Nonetheless, no member can transfer its obligation to provide best execution to another member. Therefore, all member firms have an obligation to conduct an independent review for execution quality (see NASD Notice to Members 01-22). FINRA Regulation “believes that an introducing broker/dealer must take reasonable steps to ensure that the introducing broker/dealer and its executing broker/dealer are complying with the duty of best execution. An introducing firm that routes its order flow to its clearing firm…can rely on the clearing firm’s regular and rigorous review as long as the statistical results and rationale of the review are fully disclosed to the introducing firm and the introducing firm periodically reviews how the clearing firm is conducting that review, as well as the results of that review.” Additionally, any correspondent who uses a “customized” routing table and/or routes a material number of orders “away,” and/or directs a material number of orders via RBC C&C’s order routing systems to specific destinations, may not be able to rely at all on the regular and rigorous review performed by RBC C&C.
For more information, please visit the RBC C&C Page here.