Policies and Disclosures

Alternative Account Access

You may access your Greenmoor Financial Group Account from any computer that has access to the Internet. Customers trading on-line may have difficulty accessing their accounts due to high Internet traffic or because of systems capacity limitations. If for any reason you are unable to access your account via your Internet service provider, you should phone-in any order requests by contacting Greenmoor Financial Group’s Trade Desk @ (312) 268-1265 and a licensed representative will promptly assist you.

Please do not send any orders via e-mail, instant messaging or to the Firm’s Trade Desk voice mailbox

Greenmoor Financial Group, LLC does not accept transaction orders in this manner nor will we be held responsible for any orders sent to the firm in this fashion.

Business Continuity Plan
Customer Disclosure

Greenmoor Financial Group, LLC has developed a Business Continuity Plan (the “BCP”) concerning 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 BCP.

Our Business Continuity Plan – We plan to attempt 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 BCP is designed to permit us to resume operations as quickly as possible, given the scope and severity of the significant business disruption

Our BCP addresses the following: 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 backs up your account records and stores them in a geographically remote location. Nonetheless, your orders and requests for funds and securities could be delayed in the event of a significant business disruption.

Varying Disruptions – Significant business disruptions can vary in their scope. They may affect only our firm, a single building housing our firm, the business district where we are 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 may transfer our operations to a local site when needed. In a disruption affecting our business district, city, or region, we may transfer our operations to a site outside of the affected area. In either situation, we plan to attempt to continue in business, transfer operations to the clearing firm if necessary, and notify you through our website or through any other means that remain available to us, how you can 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 by phone at 312-960-6700, by fax at 312-960-6710, or by e-mail at jschwartz@gcmtrading.com

E-Confirmations and E-Statements

Greenmoor Financial Group provides daily trade confirmations and monthly account statements via our website atGFGtrading.com

After logging into your GFG Trading Account, you will be able to review your E-Confirmations for the previous three months and your E-Statements for the current year and the prior year. There is no charge for this service

Day Trading And Margin Requirements

You may be deemed a “Pattern Day Trader” based on the following means:

  • If you execute four (4) or more day trades -opening and then closing a position in the same stock or option contract on the same day - within a five (5) business day period.
  • If you state on the new account application form “I do intend to use the account for day-trading purposes.”
  • If you advise the firm in writing that you intend to day trade.

The minimum equity requirement for a pattern day trading account is $25,000. Day trading activity of any kind is not permitted in a margin account that starts the trading day with less than $25,000 in equity.

Pursuant to NASD Rule 2520(f)(8)(B), day trading accounts and pattern day trading accounts must maintain $25,000 in equity at all times.  Additionally, trading activity in the account is limited by the amount of account’s “day-trading buying power” as that term is defined in the rule.  For additional information and or a copy of the rule, please contact Greenmoor Financial Group, LLC.  An on-line version of NASD/FINRA rules may also be viewed on the FINRA web site at www.finra.org.

If you are a “Pattern Day Trader" and are unable to deposit funds and/or securities to raise your account equity to $25,000 or more, you must discontinue day trading immediately.

If you no longer intend to day trade, but would like to maintain your account as a margin account, notify the firm in writing, signed by all account holders and we will reinstate your account as a non-day trading margin account.

If you would like to continue to day trade with “Settled Funds,” notify the firm in writing, signed by all account holders, that you would like your account to be changed to a cash account. If you change your account to a cash account, you need to be aware of the following:

  • If you choose to change to a cash account, you must remain a cash account for ninety (90) days. After 90 days if you would like your account to be changed back to a margin account, you must complete a new margin agreement and submit for approval.
  • Cash accounts may only day trade with “Settled Funds” – this means that if you buy and sell the same security on the same day, you will be unable to use the sales proceeds until the settlement date for the sell transaction. Settlement is one (1) business day after trade date for options and three (3) business days for equities.
  • Cash accounts that day trade are required to maintain $25,000 in account equity.
  • Cash accounts may not sell stocks short.
  • Cash accounts will not be approved for spreads, straddles or uncovered option transactions of any kind.
  • The firm will accept a written request to switch your margin account to a cash account if you do not have a margin debit balance, or hold a spread, straddle or uncovered option position in the account.
Day Trading Risk Disclosure Statement

You should consider the following points before engaging in a day-trading strategy. For purposes of this notice, a “day-trading strategy” means an overall trading strategy characterized by the regular transmission by a customer of intra-day orders to effect both purchase and sale transactions in the same security or securities.

Day trading can be extremely risky. Day trading generally is not appropriate for someone of limited resources and limited investment or trading experience and low risk tolerance. You should be prepared to lose all of the funds that you use for day trading. In particular, you should not fund day trading activities with retirement savings, student loans, second mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required to meet your living expenses. Further, certain evidence indicates that an investment less than $50,000 will significantly impair the ability of a day trader to make a profit. Of course, an investment of $50,000 or more will in no way guarantee success.

Be cautious of claims of large profits from day trading. You should be wary of advertisements or other statements that emphasize the potential for large profits in day trading. Day trading can also lead to large and immediate financial losses.

Day trading requires knowledge of securities markets. Day trading requires in-depth knowledge of the securities markets and trading techniques and strategies. In attempting to profit through day trading, you must compete with professional, licensed traders employed by securities firms. You should have appropriate experience before engaging in day trading.

Day trading requires knowledge of a firm’s operations. You should be familiar with a securities firm’s business practices, including the operation of the firm’s order execution systems and procedures. Under certain market conditions, you may find it difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a stock suddenly drops, or if trading is halted due to recent news events or unusual trading activity. The more volatile a stock is, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to system failures.

Day trading will generate substantial commissions, even if the per trade cost is low. Day trading involves aggressive trading, and generally you will pay commissions on each trade. The total daily commissions that you pay on your trades will add to your losses or significantly reduce your earnings. For instance, assuming that a trade costs $16 and an average of 29 transactions are conducted per day, an investor would need to generate an annual profit of $111,360 just to cover commission expenses.

Day trading on margin or short selling may result in losses beyond your initial investment. When you day trade with funds borrowed from a firm or someone else, you can lose more than the funds you originally placed at risk. A decline in the value of the securities that are purchased may require you to provide additional funds to the firm to avoid the forced sale of those securities or other securities in your account. Short selling as part of your day-trading strategy also may lead to extraordinary losses, because you may have to purchase a stock at a very high price in order to cover a short position.

Potential Registration Requirements. Persons providing investment advice for others or managing securities accounts for others may need to register as either an “Investment Advisor” under the Investment Advisors Act of 1940 or as a “Broker” or “Dealer” under the Securities Exchange Act of 1934. Such activities may also trigger state registration requirements.

Margin Disclosure Statement

Pursuant to FINRA rules, Greenmoor Financial Group.LLC 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 your firm. Consult your firm regarding any questions or concerns you may have with your margin accounts.

When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firm’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, the firm 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 the firm that has made the loan to avoid the forced sale of those securities or other securities or assets in your account(s).
  • The 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 the firm’s higher “house” requirements, the firm 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 short fall in the account after such a sale.
  • The firm 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 firm cannot liquidate securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempts to notify their customers of margin call , 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 customers.
  • 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, the firm has the right to decide which security to sell in order to protect its interests.
  • The 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 the member 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 an extension.
Market Data Disclosure

Information providers, to include securities markets and exchanges that make market data available, or other entities that provide market data, have proprietary interests in the market data that they make available.

Stock quotes displayed by Greenmoor Financial Group, LLC are provided by outside vendors, and Greenmoor Financial Group, LLC does not guarantee the accuracy of any quote information you may receive. The information providers do not guarantee the accuracy, timeliness or completeness of any market data they disseminate and you may not hold Greenmoor Financial Group, LLC responsible for an injury associated with any trade made in reliance upon such quote information.

You acknowledge that the market data you receive through Greenmoor Financial Group, LLC is the property of the information providers and that you may use this market data only for your personal use and that you may not re-transmit this data for any business purposes.

Payment For Order Flow

Industry regulations require that Greenmoor Financial Group, LLC disclose whether is receives compensation for directing customer orders for execution to various dealers, exchanges or market centers. This compensation is commonly referred to as “payment for order flow.” The firm routes customer orders for execution to various dealers, exchanges and market center, some of which pay for such order flow. Details of such payments are included in confirmations of transactions, periodic statements, or upon request of a customer.

Information Required From Individuals:
  • The identity and address of the customer (Post Office boxes are not acceptable)
  • Date of Birth
  • Social Security number or Taxpayer Identification number
  • Copy of valid government issued photo identification such as a driver’s license or passport (passport required for all non-resident aliens)
  • Investment experience and objective
  • Net worth, liquid net worth and annual income
  • Citizenship status (e.g. U.S. citizen, resident alien with nationality, non-resident alien
  • Occupation, employer, employer’s address and nature of the customer’s employment/business
  • The source of the customer’s assets

Additional information may be required from Companies, Trusts, Partnerships or other Legal Entities

When a prospective customer fails to provide any of the required information, Greenmoor Financial Group, LLC will deny the application and not open the account.

Privacy Statement

Greenmoor Financial Group, LLC has a strict policy of protecting the confidentiality and security of information we collect about our clients. We do not share information about you outside of Greenmoor Financial Group, LLC without your expressed consent except as described.

In establishing an account with Greenmoor, it is necessary that you provide the firm with certain personal information necessary to ensure that your account is managed consistent with your investment objectives and personal financial goals. This information will generally be derived from the following sources:

  • Information we receive from you on the New Account Form or other forms, and
  • Information about your securities transactions with the firm or advisors that may be providing financial services to you

It is the policy of Greenmoor that we do not disclose any non-public personal information about you to anyone except as required by law or court order. Information is shared with third party service providers only as necessary to settle transactions in your account.

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

Greenmoor restricts access to your personal and account information to those employees who need to know that information to provide service to you. The firm maintains physical, electronic and procedural safeguards to guard tour non-public personal information.

Customer Identification Program Notice
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 account, we will ask for your name, address, date of birth and identification number. The identification for a U.S. citizen would be a taxpayer identification number. For a non- U.S. citizen the identification number would include the taxpayer identification number, passport number, and country of issuance, alien identification number, or government-issued identification showing nationality, residence, and a photograph of you. We may also ask to see your driver’s license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement.

Should you have any questions please contact Jeffrey Schwartz at 312-960-6700, by fax 312-960-6710 or by e-mail jschwartz@gcmtrading.com.

Stock Market Volatility Disclosure High Volume, High Volatility and Trading Halts

Recent events show that the way some stocks are traded is changing dramatically, and the change in trading methods may affect price volatility and cause increased trading volume. This price volatility and increased volume present new hazards to investors, whether trading occurs on-line or otherwise.

Delays

A fast market is a high-volume trading session marked by extreme price fluctuations and order imbalances resulting from numerous investors entering buy or sell orders for the same security simultaneously. Because of these imbalances, wide price variances in short periods of time are common. On any given day, fast markets can affect a particular security, groups of securities or the market as a whole. Fast markets can be caused by material news announcements, market developments, and sometimes trading halts in less volatile securities. The ability to execute orders in a timely manner in fast market conditions may be severely limited and order execution may be delayed significantly. Furthermore, Market orders entered in fast market conditions may be executed at prices that are significantly different from the prices quoted at the time

Types of Orders

“Market” orders are orders that firms are required to execute fully and promptly without regard to price. While a customer may receive a prompt execution of a market order, the execution may be at a price significantly different from the current quoted price of that security.

“Limit” orders are orders that will only be executed at a specified price or better. Though the customer receives price protection, there is the possibility the order will not be executed at all.

Customers who place market orders for initial public offering (IPO) securities trading in the secondary market, particularly those trading at a premium to their offering (IPO) price, risk receiving an execution substantially away from the market price at the time they place the order. This risk may be significantly reduced by including a cap (or floor) with the order above (or below) which the order is not to be executed. This can be done by placing a Limit order.

Access

Customers may suffer market losses during periods of volatility in the price and volume of a particular stock when systems problems result in the inability to place buy or sell orders. Customers trading on-line may have difficulty accessing their accounts due to high Internet traffic or because of systems capacity limitations. Customers trading through representatives of on-line firms when on-line trading has been disabled or is not available because of systems limitations may have difficulty reaching account representatives on the telephone during periods of high volume.

Margin

Greenmoor Financial Group, LLC may raise margin requirements for volatile stocks. The rationale for raising maintenance margin is to help ensure that the equity in a customer’s margin account is sufficient to cover large changes in the price of a stock. The Firm will evaluate stocks for more stringent maintenance margin requirements by examining price fluctuations, market capitalization and volatility. The firm may also prohibit the use of margin to purchase certain securities. Some securities may be designated as “not marginable,” thus requiring customers to purchase the securities with 100% initial margin, allowing payment to be made within three (3) days of settlement.

Trading Halts

Trading may be halted temporarily for a single issue of securities or for all securities listed on Nasdaq or on an exchange (a circuit breaker halt). All trading in a halted security must cease immediately. No transactions in a halted security may be effected directly or indirectly until the halt has ended. During trading halts that will be lifted so as to allow trading to resume on the same trading day, pending and new customer orders will be forwarded to the appropriate market for execution upon resumption of trading, unless the customer indicates otherwise. During trading halts that close the market for the remainder of the trading day, pending and new customer orders will be handled as follows:

  • Orders that are pending at the time of the halt and new orders received during the halt will be treated as “Good Till Cancelled” orders and held for execution at the reopening of the next trading session, unless the customer indicates otherwise.
  • “At the Close” orders pending at the time trading is halted will be treated as cancelled orders
  • New orders related to closing prices will not be accepted or forwarded to a market during a trading halt.
  • SIPC Protection
SIPC Protection

Greenmoor Financial Group, LLC is a member of the Securities Investor Protection Corporation (“SIPC”), which currently provides the securities customers of its members up to $500,000 cash & securities coverage (maximum cash coverage is $100,000).

This account protection does not cover the market risks associated with investing.

An explanatory brochure is available upon request or at http://www.sipc.org