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NOTICE OF PRIVACY PRACTICES
Herndon Plant Oakley Ltd. and its affiliates
American Investment Services
Herndon Plant Oakley Ltd., Registered Investment Advisor
Congress recently passed the Gramm-Leach Bliley (GLB) Act, which deals in part with how financial institutions treat nonpublic personal financial information. Herndon Plant Oakley Ltd. has always been committed to maintaining customer confidentiality. We appreciate this opportunity to clarify our privacy practices for you as a result of this new law.
Information We Collect
Herndon Plant Oakley Ltd. collects personal, non-public information about you from applications or other forms you provide us; transactional history in your account (for example trading history and balances) and from interactions with Herndon Plant Oakley Ltd. (for example, discussions with your representative or members of their staff).
Information We Share
We may exchange individual investors' information, as described above, with our affiliates, in order to offer products and services. We may also share this individual investor information, under joint marketing agreements with nonaffiliated financial services business partners, in order to offer access to their products and services. We may also share this information with companies as necessary to process your business (for example, clearing firms), where required by law or regulation.
We also make disclosures to other nonaffiliated third parties as authorized or permitted by law.
Confidentiality and Security
We restrict access to information about you to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to maintain the confidentiality of your information.
If you decide to close your account with us, we will continue to adhere to the privacy policies and practices as described in this notice.
We do not sell your personal information to anyone. And we do not share it with anyone outside the Herndon Plant Oakley family and those we work with to provide you products and services.
You do not need to call, or do anything as a result of this notice. It is meant to inform you of how we safeguard your nonpublic personal financial.
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SEC-REQUIRED DISCLOSURE: Report on Routing of Customer Orders
Herndon Plant Oakley Ltd (HPO) has
provided information pursuant to a U.S. Securities and
Exchange Commission rule (11Ac1-6) that requires firms to
make publicly available, quarterly reports on the firm's
order routing practices. The report provides information on
the routing of "non-directed orders" which is generally
defined as any order that the client has not specifically
instructed to be routed to a particular venue for execution.
For these non-directed orders, HPO has selected
the execution venue on behalf of its clients through it's
clearing firm First Clearing Correspondent Services (FCCS).
The report is divided into four sections: one for securities
listed on the New York Stock Exchange, one for securities
listed on The Nasdaq Stock Market, one for securities listed
on the American Stock Exchange or regional exchanges, and
one for exchange-listed options.
For each section, this report identifies the venues most often
selected by our clearing firm, First Clearing Correspondent Services (FCCS), sets forth the percentage of
various types of orders routed to the venues, and discusses
the material aspects of FCCS's relationship with the
venues.
When you select this link you will be leaving the HPO Web site.
http://www.tta.thomson.com/reports/index.html?clientid=fccp
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BUSINESS CONTINUITY PLAN CLIENT DISCLOSURE STATEMENT
Herndon Plant Oakley, Ltd. 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 after a significant business disruption you cannot contact us as you usually do at 1-800-888-4894 or bragan@hpo.com, you should call our alternative number 281-340-2030 or go to our web site at www.hpo.com. If you cannot access us through either of those means, you should contact our clearing firm, First Clearing Correspondent Services., at 800-727-0304 or http://www.firstclearingllc.com/index.htm for instructions on how it may provide custody services, order execution, order comparison, order allocation, access to customer funds and securities, and clearance and settlement services.
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, First Clearing 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 4 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 24 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 24 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.hpo.com or our customer emergency number, 281-340-2030 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 1-800-888-4894.
This plan is subject to modification, an updated summary will be promptly posted on our Web site and customers may alternatively obtain updated summaries by requesting a written copy by mail.
Last Updated: 29th August, 2008
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Member FINRA / SIPC FR2002-0607-0029 |
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