Privacy Policy Disclosure

Privacy Statement for Individuals

            As a Sutter Securities’ client, your privacy is important to us.  Reflecting the Firm's commitment to protecting the privacy of your personal information, we have implemented privacy policies consistent with the rules mandated by federal guidelines for financial institutions.  We have also adopted policies and procedures designed to help ensure the security and confidentiality of our customers' records and information.

The collection of personal information

            In order to help us provide the best level of service, better meet your financial needs, and provide the financial services that Sutter Securities offers, we may collect information from the following sources:

• Applications and other forms we have filled out (including information such as your name, address, social security number and income);

• Your transactions with us, our affiliates, or others (including information such as account balances and transaction history);

• Credit reporting agencies (who provide us with your credit history and information to protect both you and Sutter Securities against fraud).

Disclosure of personal information to nonaffiliated

third parties for business purposes

            We may disclose the information described above to companies that are not affiliated with Sutter Securities for business purposes in the following circumstances:

• Companies  that perform administrative services on our behalf (such as vendors that provide data processing, transaction processing and printing services);
• Our clearing broker.

Disclosure of personal information in other instances

            Sutter Securities currently does not share information with third parties not affiliated with the Firm, such as mortgage bankers, securities broker-dealers (other than our clearing broker-dealer) and insurance agents. Please feel free to contact our Compliance Department at 415-352-6340 if you have any additional questions.

            In addition, we may also disclose the information described above to nonaffiliated third parties as permitted by law, for example, to comply with a subpoena, respond to a regulatory authority or to protect against fraud.

Information Confidentiality and Security

            At Sutter Securities, we restrict access to client information to those employees who need to know such information in order to perform their job responsibilities.  Employees who have access to client information must adhere to our strict security and confidentiality policies.

Former Customers

Information of former clients will be treated as described in this policy.

Business Continuity Plan (BCP)

            Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business.  In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities. 

            Sutter is an introducing firm and does not perform any type of clearing function.  Furthermore, we do not hold customer funds or securities.  We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking.  Our clearing firm, Pershing LLC, a subsidiary of the Bank of New York Mellon Corporation, provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. 

            In the event of an internal or external SBD, Sutter will post on our web site how customers may access their funds and securities by contacting Pershing LLC. 

Anti-Money Laundering Customer Information

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 for 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. All major financial receipts and transfers may be subject to review.