Disclaimer of
Warranty and Limitation of Liability
The information on this site is provided "AS IS".
Wunderlich Securities, Inc. (“Wunderlich”) does not
warrant the accuracy of the materials provided
herein, either expressly or impliedly, for any
particular purpose and expressly disclaims any
warranties of merchantability or fitness for a
particular purpose. This information is for
informative purposes only and is not intended as an
offer or solicitation with respect to the purchase
or sale of any product. Wunderlich will not be
responsible for any loss or damage that could result
from interception by third parties of any
information made available to you via this site.
Although the information provided to you on this
site is obtained or compiled from sources we believe
to be reliable, Wunderlich cannot and does not
guarantee the accuracy, validity, timeliness or
completeness of any information or data made
available to you for any particular purpose. Neither
Wunderlich, nor any of its affiliates, directors,
officers or employees, nor any third party vendor
will be liable or have any responsibility of any
kind for any loss or damage that you incur in the
event of any failure or interruption of this site,
or resulting from the act or omission of any other
party involved in making this site or the data
contained therein available to you, or from any
other cause relating to your access to, inability to
access, or use of the site or these materials,
whether or not the circumstances giving rise to such
cause may have been within the control of Wunderlich
or of any vendor providing software or services
support. In no event will Wunderlich, its affiliates
or any such parties be liable to you for any direct,
special, indirect, consequential, incidental damages
or any other damages of any kind even if Wunderlich
or any other party have been advised of the
possibility thereof.
Routing and
Execution Disclosures Made Pursuant to Rule 605
Rule 605 of SEC Regulation NMS requires "market
centers" to publicly disclose, on a monthly basis,
certain statistical information relating to the
quality of executions provided to eligible client
orders. The information generally depicts how
orders of various sizes are executed relative to
public quotes existing at the time of order receipt,
and also attempts to measure speed of execution.
The Rule 605 statistics for Wunderlich are available
for public review by
clicking here.
Routing and
Execution Disclosures Made Pursuant to SEC Rule 606
Rule 606 of SEC Regulation NMS requires
broker-dealers receiving non-directed client orders
to publicly disclose, on a quarterly basis, the top
execution venues to which such orders are routed for
execution. Broker-dealers also must disclose
material aspects of the relationships they maintain
with the identified execution venues. The Rule 606
statistics for Wunderlich are available for public
review by clicking
here.
USA PATRIOT Act
In response to the terrorist attacks on
September 11, 2001 , the
US Congress passed the USA PATRIOT Act. Parts of
this Act apply to the financial services industry
and require certain financial institutions to
request specific information from clients.
Under the USA PATRIOT Act and other regulations,
financial services firms must establish a compliance
program, which includes policies and procedures to
detect and report suspicious transactions to the
government, as well as ensure compliance with the
new laws. Firms must also implement specialized
employee training programs, designate a special
compliance officer and conduct independent audits of
the effectiveness of the compliance program.
Wunderlich has named an anti-money-laundering
officer. In conjunction with First Clearing
Corporation, we are implementing a suspicious
activity reporting system that will enable us to
better report suspicious activity to the government.
All of our employees are being trained in
anti-money-laundering practices and procedures, as
well as the details of the firm's policies.
The regulations also impose new requirements
regarding client information and verification of
that information. Financial services firms are
required to verify the identity of the clients with
whom they do business, where appropriate determine
the source of funds in a client's account and obtain
the information about a client's wealth.
At Wunderlich we have always known the importance of
knowing our clients and that the better we know our
clients, the better we can serve their financial
needs. As part of our compliance with the new Act
and in support of the fight against money laundering
around the world, we may ask clients for additional
information and documentation about certain accounts
and transactions. This information may be used to
verify client identity.
Notice of Privacy Policy
This notice is being provided to every customer by
Wunderlich Securities, Inc, because we are committed
to keeping the personal information collected from
our potential, current and former customers
confidential and secure. The proper handling of
personal information is one of our highest
priorities. We want to be sure that you know why we
need to collect personal information from you. We
also want to explain to you our commitment to
protect the information you provide to us. We never
sell your information to any outside parties.
Customer Information
We collect and keep only information that is
necessary for us to provide services requested by
you and to administer your business with us. We may
collect nonpublic personal information:
§
From you when you complete an application or other
form. This includes information such as name,
address, social security number, assets, income, net
worth and other information deemed necessary to
evaluate your financial needs.
§
From a consumer-reporting agency for information
such as your credit history as authorized by you.
§
Information about your transactions and your account
experience, including your account balances, trading
activity and payment history.
§
As a result of transactions with us, or with our
affiliates or others. This could include
transactions completed with us, information received
from outside vendors to complete transactions or to
effect planning goals.
Sharing Information
We only share your nonpublic personal information
with non-affiliated companies or individuals as
permitted by law, such as your representative within
our firm, securities clearing firm, mutual funds,
insurance companies and other product vendors, or to
comply with legal or regulatory requirements. In the
normal course of our business, we may disclose
information we collect about you to companies or
individuals that contract with us to perform
servicing functions such as:
§
Record keeping
§
Computer related services
§
Third party money managers
§
Good faith disclosure to regulators who have
regulatory authority over the company.
Companies we hire to provide support services are
not allowed to use your personal information for
their own purposes and are contractually obligated
to maintain strict confidentiality. We limit their
use of your personal information to the performance
of the specific service we have requested. Companies
we hire to provide support services are not allowed
to use your personal information for their own
purposes and are contractually obligated to maintain
strict confidentiality. We limit their use of your
personal information to the performance of the
specific service we have requested. We do not
provide your personally identifiable information to
mailing list vendors or solicitors for any purpose.
When we provide personal information to a service
provider, we require these providers to agree to
safeguard your information, to use the information
only for the intended purpose, and to abide by
applicable law.
We do not provide your personally identifiable
information to mailing list vendors or solicitors
for any purpose.
Internet Access
We provide a website on the Internet for our company
which is informational only and in no way
compromises your privacy since we gather no personal
information from you. We do not utilize Cookies,
Graphics Interchange Format (GIF's), or any other
web tools. You should check the privacy policy for
any links provided upon leaving our web site.
We provide access to your securities accounts via
the Internet. Your password is your private entry
key into your account. You should never share
website access information with anyone and you
should change it periodically.
After you've finished accessing your securities
account, please log off to prevent someone else from
accessing your account.
Employee Access to Information
Only employees with a valid business reason have
access to your personal information. These employees
are educated on the importance of maintaining the
confidentiality and security of this information.
They are required to abide by our information
handling practices.
Protection of Information
We maintain security standards to protect your
information, whether written, spoken, or electronic.
We update and test our systems to ensure the
protection and integrity of information
NASD Investor Brochure
In accordance with NASD Rule 2280, Wunderlich
Securities, Inc. is providing the following
information in the event you wish to contact the
NASD. You may contact the NASD via telephone at
301-590-6500 or by mail at 1735 K Street NW,
Washington, DC 20006-1500. In addition to the
public disclosure number (800-289-9999), the NASD
provides an investor brochure that describes their
Public Disclosure Program. Additional information
is also available at
www.NASD.com
MSRB Information for Municipal Securities Investors
To satisfy the requirements of MSRB rule G-10, an
investor brochure describing Board rulemaking
authority, the rules protecting the investor,
arbitration and communication with the industry and
investors is available to you upon request. Please
ask your broker for more information or visit the
MSRB website for more information at
http://www.msrb.org/msrb1/custrule.htm
Margin Disclosure Statement
Wunderlich Securities, Inc. (“WSI”) is furnishing
this document to you to provide some basic facts
about purchasing securities on margin, and to alert
you to the risks involved with trading securities in
a margin account. Before trading stocks in a margin
account, you should carefully review the margin
agreement provided by WSI. Please contact your
broker regarding any questions or concerns you may
have with your margin account(s).
When you purchase securities through WSI, you may
pay for the securities in full or you may borrow
part of the purchase price from WSI’s clearing firm,
First Clearing Corporation (“FCC”). If you choose to
borrow funds, you will need to open a margin account
with WSI. The securities purchased are First
Clearing's collateral for the loan to you. If the
securities in your account decline in value, so does
the value of the collateral supporting your loan.
And, as a result, FCC or WSI can take action, such
as issue a margin call and/or sell securities or
other assets in any of your accounts held with the
member, in order to maintain the required equity in
the account.
It is important that you fully understand the risks
involved in trading securities on margin. These
risks include the following:
You can
lose more funds than you deposit in the margin
account.
A decline in the value of securities that are
purchased on margin may require you to provide
additional funds to FCC, the firm that has made the
loan, to avoid the forced sale of those securities
or other securities or assets in your accounts).
FCC or WSI firm can force the sale of securities or
other assets in your account(s).
If the equity in your account falls below the
maintenance margin requirements or FCC's higher
"house" requirements, FCC can sell the securities or
other assets in any of your accounts held at the
firm to cover the margin deficiency. You also will
be responsible for any shortfall in the account
after such a sale.
FCC or WSI can sell your securities or other assets
without contacting you.
Some investors mistakenly believe that a firm must
contact them for a margin call to be valid, and that
the brokerage firm cannot liquidate securities or
other assets in their accounts to meet the call
unless the brokerage firm has contacted them first.
This is not the case. Most firms will attempt to
notify their customers of margin calls, but they are
not required to do so. However, even if a firm has
contacted a customer and provided a specific date by
which the customer can meet a margin call, the firm
can still take necessary steps to protect its
financial interests, including immediately selling
the securities without notice to you.
You are not entitled to choose which securities or
other assets in your account(s) are liquidated or
sold to meet a margin call.
Because the securities are collateral for the margin
loan, FCC or WSI has the right to decide which
security to sell in order to protect its interests.
FCC or WSI firm can increase its "house" maintenance
margin requirements at any time and is not required
to provide you advance written notice.
These changes in firm policy often take effect
immediately and may result in the issuance of a
maintenance margin call. Your failure to satisfy the
call may cause FCC or WSI to liquidate or sell
securities in your account(s).
You are not entitled to an extension of time on a
margin call.
While an extension of time to meet margin
requirements may be available to customers under
certain conditions, a customer does not have a right
to the extension.
Securities in your margin account may be loaned to
or by FCC. To the extent FCC determines, in
accordance with Federal tax regulations, that your
securities have been loaned, payments received by
you with respect to such securities (including
payments in lieu of dividends) may be reclassified
as substitute payments. Substitute payments may be
reported on different tax reporting forms than
payments received on the underlying securities and
may be subject to different tax consequences and
rates. You are advised to contact your tax advisor
to discuss the tax treatment of substitute payments.
Breakpoint Disclosure Statement
Before investing in mutual funds, it is important
that you understand the sales charges, expenses, and
management fees that you will be charged, as well as
the breakpoint discounts to which you may be
entitled. Understanding these charges and breakpoint
discounts will assist you in identifying the best
investment for your particular needs and may help
you reduce the cost of your investment. This
disclosure will give you general background
information about these charges and discounts.
However, sales charges, expenses, management fees,
and breakpoint discounts vary from mutual fund to
mutual fund. Therefore, you should discuss these
issues with your financial advisor and review each
mutual fund’s prospectus and statement of additional
information, which are available from your financial
advisor, to get the specific information regarding
the charges and breakpoint discounts associated with
a particular mutual fund.
Sales Charges
Investors that purchase mutual funds must make
certain choices, including which funds to purchase
and which class share is most advantageous. Each
mutual fund has a specified investment strategy. You
need to consider whether the mutual fund’s
investment strategy is compatible with your
investment objectives. Additionally, most mutual
funds offer different share classes. Although each
share class represents a similar interest in the
mutual fund’s portfolio, the mutual fund will charge
you different fees and expenses depending upon your
choice of share class. As a general rule, Class A
shares carry a “front-end” sales charge or “load”
that is deducted from your investment at the time
you buy fund shares. This sales charge is a
percentage of your total purchase. As explained
below, many mutual funds offer volume discounts to
the front-end sales charge assessed on Class A
shares at certain pre-determined levels of
investment, which are called “breakpoint discounts.”
In contrast, Class B and C shares usually do not
carry any front-end sales charges. Instead,
investors that purchase Class B or C shares pay
asset-based sales charges, which may be higher than
the charges associated with Class A shares.
Investors that purchase Class B and C shares may
also be required to pay a sales charge known as a
contingent deferred sales charge when they sell
their shares, depending upon the rules of the
particular mutual fund.
Breakpoint Discounts
Most mutual funds offer investors a variety of ways
to qualify for breakpoint discounts on the sales
charge associated with the purchase of Class A
shares. In general, most mutual funds provide
breakpoint discounts to investors who make large
purchases at one time. The extent of the discount
depends upon the size of the purchase. Generally, as
the amount of the purchase increases, the percentage
used to determine the sales load decreases. In fact,
the entire sales charge may be waived for investors
that make very large purchases of Class A shares.
Mutual fund prospectuses contain tables that
illustrate the available breakpoint discounts and
the investment levels at which breakpoint discounts
apply. Additionally, most mutual funds allow
investors to qualify for breakpoint discounts based
upon current holdings from prior purchases through “Rights
of Accumulation,” and future purchases, based
upon “Letters of Intent.” This document
provides general information regarding Rights of
Accumulation and Letters of Intent.
However, mutual funds have different rules regarding
the availability of Rights of Accumulation
and Letters of Intent. Therefore, you should
discuss these issues with your financial advisor and
review the mutual fund prospectus to determine the
specific terms upon which a mutual fund offers
Rights of Accumulation or Letters of Intent.
Rights of Accumulation
Many mutual funds allow investors to count the value
of previous purchases of the same fund, or another
fund within the same fund family, with the value of
the current purchase, to qualify for breakpoint
discounts. Moreover, mutual funds allow investors to
count existing holdings in multiple accounts, such
as IRAs or accounts at other broker-dealers, to
qualify for breakpoint discounts. Therefore, if you
have accounts at other broker-dealers and wish to
take advantage of the balances in these accounts to
qualify for a breakpoint discount, you must advise
your financial advisor about those balances. You may
need to provide documentation establishing the
holdings in those other accounts to your financial
advisor if you wish to rely upon balances in
accounts at another firm.
In addition, many mutual funds allow investors to
count the value of holdings in accounts of certain
related parties, such as spouses or children, to
qualify for breakpoint discounts. Each mutual fund
has different rules that govern when relatives may
rely upon each other’s holdings to qualify for
breakpoint discounts. You should consult with your
financial advisor or review the mutual fund’s
prospectus or statement of additional information to
determine what these rules are for the fund family
in which you are investing. If you wish to rely upon
the holdings of related parties to qualify for a
breakpoint discount, you should advise your
financial advisor about these accounts. You may need
to provide documentation to your financial advisor
if you wish to rely upon balances in accounts at
another firm.
Mutual funds also follow different rules to
determine the value of existing holdings. Some funds
use the current net asset value (NAV) of existing
investments in determining whether an investor
qualifies for a breakpoint discount. However, a
small number of funds use the historical cost, which
is the cost of the initial purchase, to determine
eligibility for breakpoint discounts. If the mutual
fund uses historical costs, you may need to provide
account records, such as confirmation statements or
monthly statements, to qualify for a breakpoint
discount based upon previous purchases. You should
consult with your financial advisor and review the
mutual fund’s prospectus to determine whether the
mutual fund uses either NAV or historical costs to
determine breakpoint eligibility.
Letters of Intent
Most mutual funds allow investors to qualify for
breakpoint discounts by signing a Letter of Intent,
which commits the investor to purchasing a specified
amount of Class A shares within a defined period of
time, usually 13 months. For example, if an investor
plans to purchase $50,000 worth of Class A shares
over a period of 13 months, but each individual
purchase would not qualify for a breakpoint
discount, the investor could sign a Letter of Intent
at the time of the first purchase and receive the
breakpoint discount associated with $50,000
investments on the first and all subsequent
purchases. Additionally, some funds offer
retroactive Letters of Intent that allow investors
to rely upon purchases in the recent past to qualify
for a breakpoint discount. However, if an investor
fails to invest the amount required by the Letter of
Intent, the fund is entitled to retroactively deduct
the correct sales charges based upon the amount that
the investor actually invested. If you intend to
make several purchases within a 13 month period, you
should consult your financial advisor and the mutual
fund prospectus to determine if it would be
beneficial for you to sign a Letter of Intent.
As you can see, understanding the availability of
breakpoint discounts is important because it may
allow you to purchase Class A shares at a lower
price. The availability of breakpoint discounts may
save you money and may also affect your decision
regarding the appropriate share class in which to
invest. Therefore, you should discuss the
availability of breakpoint discounts with your
financial advisor and carefully review the mutual
fund prospectus and its statement of additional
information, which you can get from your financial
advisor, when choosing among the share classes
offered by a mutual fund. If you wish to learn more
about mutual fund share classes or mutual fund
breakpoints, you may wish to review the investor
alerts available on the NASD Web site. See
www.nasdr.com/alert_mfclasses.htm,
http://www.nasd.com/Investor/Alerts/alert_breakpoint.htm
or visit mutual fund Web sites available to the
public.
Business Continuity Plan
This document provides a general overview of the
Business Continuity Plan ("BCP") for Wunderlich
Securities, Inc ("Wunderlich”). A BCP is a program
designed to help ensure that we can continue to do
business even if we experience an unplanned business
interruption such as a loss of utility service, a
building evacuation, or a catastrophic event.
Wunderlich's BCP addresses the action that we will
take in the event that a significant business
disruption ("SBD”) affects a single building, a
business district, a citywide area, or an entire
region. We have different planned recovery times
depending on the severity of the SBD. In the event
of a branch outage, the telephones to the branch
office experiencing the SBD will be re-routed to the
main office or another branch office facility with
the ability to service the needs of the clients
within a few hours. In the event of a short term SBD
at the main office, the telephones would be
re-routed to a branch office location within several
hours. In the case of a major business disruption at
the main office, the firm has a plan to relocate the
mission-critical employees and systems to an
alternate location, which would result in a
disruption of between several hours to several days.
In regards to client assets, all of our accounts are
carried by our clearing firm, First Clearing, LLC
(“First Clearing”) and we have received and reviewed
First Clearing's BCP. We are committed to providing
continued service to out clients and to that end;
First Clearing will establish a contact number for
our clients in the event they are unable to contact
Wunderlich. In the case of an SBD affecting First
Clearing, our clients may experience additional
delays. To review First Clearing's plan please visit
www.firstclearing.com.
Additionally, the firm conducts an institutional
fixed income business for which all transactions are
done on a DVP/RVP basis through Ridge Clearing &
Outsourcing Solutions ("Ridge"). The firm has received and reviewed
Ridge's BCP. Ridge will establish a contact number
for our clients in the event they are unable to
contact Wunderlich. In the case of an SBD affecting
Ridge, our clients may experience additional delays.
To review the Ridge’s plan please visit their
website at
www.ridgeclearing.com.
Wunderlich’s BCP is subject to annual review and
update. In addition, the firm's regulators will
periodically review the BCP for compliance. As our
BCP is materially updated, you will be notified
through our Web site at
www.wunderlichsecurities.com. You may
also contact us to request a copy of our most recent
BCP by calling 1-800-726-0557.
Compliance Contact Information
We have provided
notices to you that are required by the SEC
concerning certain Wunderlich policies and
procedures. If you have any questions or complaints
regarding your account, please call Tracy Wiswall
(901) 251-1336.
Please note that: Reports of execution of
orders shall be conclusive if you do not object to
them in writing within the shorter of (i) the
applicable settlement cycle of the subject
transactions or (ii) three business days after such
documents have been transmitted to you by mail or
otherwise. Your statements of account(s) shall be
conclusive if you do not object to them in writing
within 10 days after transmission to you by mail or
otherwise. YOUR OBJECTIONS (s) MUST BE IN WRITING
AND SENT TO:
Wunderlich Securities, Inc.,
Attn: Compliance Department
6000 Poplar Avenue, Suite 150
Memphis,
TN 38119
