Privacy Policy

Pursuant to the U.S. Securities and Exchange Commission regulation entitled “Privacy of Consumer Financial Information,” otherwise referred to as “Regulation S-P,” Spencer Edwards, Inc. (“SEI”) provides the following information as it pertains to personal information you have provided in the course of establishing your customer account with us.

In order to transact securities business on your behalf, SEI collects nonpublic personal information about you from the following sources:

  • Information we receive from you on applications or other forms;
  • Information received from credit or service bureaus or other third parties; and
  • Information about your transactions with us or others.

We do not disclose any nonpublic personal information about you to anyone, except under the following circumstances:

  • To your authorized registered representative and his or her manager;
  • To establish or maintain an account with an unaffiliated third party, such as a clearing broker* providing services to you and/or SEI; and
  • To government entities or other third parties in response to subpoenas or other legal process as required by law.

If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

SEI restricts access to your personal and account information to those individuals who need to know that information to provide products or services to you.  SEI maintains physical, electronic and procedural safeguards to guard your nonpublic personal information.

SEI regularly reviews and updates its information security program to keep pace with changes in technology.

SEC REQUIRED REPORT ON ROUTING OF CUSTOMER ORDERS

All brokerage firms are required to make publicly available quarterly reports on the routing of non-directed orders. This information can be obtained via SEI’s website at www.spenceredwards.com under the “Report” section or, upon request to Customer Service at (303) 740-8448, SEI will provide you with the name of the market center or exchange utilized to execute a specific order. The specific order must have been processed within the past six (6) months from the date of your request.

SEC REQUIRED REPORT ON PAYMENT FOR ORDER FLOW

Securities and Exchange Commission (SEC) Rule 606 requires all broker/dealers disclose to their customers any payment to or from another broker dealer for order flow.  Your broker/dealer routes orders through Alpine Securities, Inc., Sterne, Agee & Leach, Inc. and COR Clearing LLC as well as other broker/dealers. Spencer Edwards, Inc. does not receive payment for order flow nor does it pay for order flow.  Securities listed on the NYSE, NASDAQ, Options and other exchanges have been routed and can be viewed at Spencer Edwards’ website or at the clearing firm’s websites, www.alpine-securities.com; www.sterneagee.com; or www.corclearing.com.

CUSTOMER COMPLAINTS

Please be advised that any customer complaints can be made in writing and directed to: Spencer Edwards, Inc., Attn:  Compliance Department, 6851 South Holly Circle, Suite 200, Centennial, CO  80112, or by facsimile to the attention of Donna Flemming, (303) 874-1090.

SECURITIES INVESTOR PROTECTION CORPORATION (“SIPC”)

Information about SIPC, including the SIPC brochure, may be obtained by contacting SIPC at www.sipc.org or call (202) 371-8300.

* SEI is an introducing securities broker-dealer. All customer transactions are cleared through another brokerdealer, Alpine Securities, Inc. or Sterne, Agee & Leach, Inc. A copy of their Privacy Policy was sent to you when your account was established with them and annually thereafter. It can be found on their website at www.alpinesecurities.com,  www.sterneagee.com , or www.corclearing.com.

To help the government fight the funding of terrorism and money laundering activities, Federal law and contractual obligations to its clearing firms require that SEI obtain my name, date of birth, address and a government issued identification number before opening my account to verify my identity.  SEI may obtain and verify this information with respect to any person(s) authorized to effect transactions in an account.  For certain entities, such as trusts, estates, corporations, partnerships or other organizations, identifying documentation is also required.  My account may be restricted and/or closed if SEI and/or Alpine Securities, Inc., Sterne Agee & Leach, Inc. or COR Clearing LLC cannot verify this information.  Neither SEI nor its clearing firms will be responsible for any losses or damages (including but not limited to lost opportunity) resulting from any failure to provide this information, or from any restriction place upon, or closing of my account.