Order Routing and Payment for Order Flow
Business Continuity Planning Statement
FINRA Public Disclosure Program
Important Information About Account Opening Procedures
Extended Hours Trading Risk Disclosures
Electronic Delivery of Notices
Notice to Australian Clients
Notice to Canadian Clients
The U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) require member firms to disclose to their customers when opening an account and at least once a year after that, their policies and procedures regarding customer identification, business continuity, trade routing, and investor protection.
Sumridge Partners, LLC (“Firm”) has created and implemented its own policies and procedures in an effort to mitigate the effects related to unforeseen business interruptions, to supply the necessary routing information about specific orders, and to provide investor protection.
Enclosed you will find our disclosure statements in those areas.
The Securities and Exchange Commission (“SEC”) requires all registered broker-dealers to disclose their policies regarding receipt of “payment for order flow.” The Commission defines “payment for order flow” as “any monetary payments, services, property, or other benefits that result in remuneration, compensation, or consideration to a broker or dealer from any broker or dealer, national securities exchange, registered securities association, or exchange member in return for the routing of customer orders by such broker or dealer to any broker or dealer, national securities exchange, registered securities association, or exchange member in return for the routing of customer orders by such broker or dealer to any broker or dealer, national securities exchange, registered securities association, or exchange member for execution, including but not limited to research, clearance, custody, products or services, reciprocal agreements for the provision of order flow adjustment of a broker or dealer’s unfavorable trading errors, effort to participate as underwriter in public offerings, stock loans or shared interest accrued thereon, discounts, rebates, or any other reductions of or credits against any fee to, or expense or other financial obligation of, the broker or dealer routing a customer order that exceeds that fee, expense or other financial obligation.”
SumRidge Partners LLC may receive from time to time remuneration in the form of rebates for providing liquidity to Electronic Communications Networks (“ECN’s”). The rebates are used to offset the cost of execution charged to SumRidge by the ECN. Any additional information concerning order flow payment will be disclosed upon written request.
Business Continuity Planning
SumRidge Partners, LLC 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 201-898-2525/Trading@Sumridge.com, you should go to our website at Sumridge.com. If you cannot access us through either of those means, you should contact our clearing firm, Pershing, LLC at 201-413-3635 for instructions.
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 backup 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.
For more information – If you have questions about our business continuity planning, you can contact us at 201-898-2525 or Compliance@sumridge.com.
The following information describes how SumRidge Partners, LLC (“SumRidge”) handle your nonpublic personal information. SumRidge may collect nonpublic personal information about you from the following sources:
1. Information we receive from you on applications or other forms; and
2. Information about your transactions with SumRidge or other third-parties, such as that pertaining to your account balance, account transactions, payment history and parties to transactions;
SumRidge does not disclose nonpublic personal information about you to anyone, except as permitted by law. Accordingly, SumRidge restricts disclosure of nonpublic personal information about you to:
1. SumRidge employees who need to know that information to provide you products or services, and
2. Non-affiliated third-parties as necessary to process your transactions, service your account or otherwise as permitted 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. SumRidge does not sell personal nonpublic information about current or former customers to any third-parties or share that information with third-parties for marketing purposes.
FINRA Public Disclosure Program
FINRA Rule 2267 requires that we notify you, in writing, about the availability of an investor brochure that includes information describing the FINRA public disclosure program, BrokerCheck. To obtain a brochure or more information about BrokerCheck, please call the FINRA BrokerCheck Hotline at (800) 299-9999. To get information on a firm or broker, go to www.finra.org, click on FINRA BrokerCheck, and follow the instructions.
Please direct all complaints to the SumRidge Partners, LLC’s Compliance Department. The Department can be reached at (201) 898-2521 or 111 Town Square Place, Suite 320, Jersey City, New Jersey, 07310
SumRidge Partners, LLC is a member of the Securities Investor Protection Corporation (“SIPC”). For more details on SIPC, or to request a SIPC brochure, visit www.sipc.org or call 1-202-371-8300.
Important Information About Account Opening Procedures
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 or entity with an account relationship.
For corporations, partnerships, trusts or other entities opening accounts with SumRidge Partners, LLC, you will be asked to provide (1) name, (2) street address, (3) a US taxpayer ID (or government issues documents for foreign entities), and (4) any other information or documents that may be necessary to verify identity.
Extended Hours Trading Risk Disclosures
You should consider the following points before engaging in extended hours trading. “Extended hours trading” means trading outside of “regular trading hours”. “Regular trading hours” generally means the time between 9:30 a.m. and 4:00 p.m. Eastern Standard Time.
- Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular trading hours. As a result, your order may only be partially executed, or not at all.
- Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
- Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
- Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
- Risk of New Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular trading hours. Similarly, important financial information is frequently announced outside of regular trading hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
- Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
For additional information, please refer to FINRA Rule 2265 and FINRA Notice to Members 00-07.
Statements; Electronic Delivery; Notices
SumRidge Partners, LLC may send you Account Notices in either electronic or paper format. You consent to and agree to accept electronic delivery of Account Notices to the extent available, other than those you may have specifically requested be delivered to you in paper form. “Account Notices” include statements, trade confirmations, notices, disclosures, regulatory communications, prospectuses, proxy solutions and privacy notices, and other information, documents, data, and other records regarding your account. Your consent to electronic delivery of Account Notices means that you accept electronic delivery in lieu of mailed paper notices, which will remain effective until you revoke such consent. So long as SumRidge Partners, LLC sends communications to you at the physical or electronic address of record given by you on the date of application, or to any other address given to us by you, the communications are legally presumed to have been delivered, whether you actually received them or not.
For Australian Clients Only
Under the Australian licensing requirements, the provision of financial services to Australian entities generally requires a financial service provider to hold an Australian Financial Services License, unless Class Order relief is granted by the Australian Securities and Investments Commission (ASIC).If you are domiciled in Australia, please be advised that SumRidge Partners, LLC is exempt from the requirement to hold an Australian financial services license under the Corporations Act 2001 of Australia (the Act) in respect of the financial services being provided to you. Please note that SumRidge Partners, LLC is primarily regulated by the U.S. Securities and Exchange Commission and the Financial Regulatory Authority under the laws of the United States of America, which differ to Australian laws.
SumRidge Partner, LLC understands that you are a wholesale client within the meaning of section 761G of the Act (Wholesale Client). SumRidge Partners, LLC may only continue to provide you with financial services pursuant to the Class Order [CO 03/1100] while you remain a Wholesale Client. Please inform you usual contact at SumRidge Partners, LLC if you are not a Wholesale Client now or if you cease to be a Wholesale Client at any time in the future.
Notice to Canadian Clients – Reliance on International Dealer Exemption
Reliance on International Dealer Exemption pursuant to subsection 8.18(2) of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations(“NI 31-103” or “the Exemption”) and Notification to Permitted Clients of the prescribed information under subsection 8.18(4)(b) of NI 31-103
Please note that as you are a client domiciled in Canada, when SumRidge Partners, LLC (SumRidge) trades with you it does so in reliance upon the international dealer exemption from the dealer registration requirement under the Exemption (as such Exemption may be amended and restated from time to time). Pursuant to the Exemption, SumRidge is currently subject to trading restrictions, including, among other things, that SumRidge is only permitted to trade “foreign securities” with “permitted clients” resident in Canada. A foreign security is a security issued by an issuer incorporated, formed or created under the laws of a foreign (i.e., non-Canadian) jurisdiction or a security issued by a government of a foreign jurisdiction. This serves to put you on notice that you should only place orders with SumRidge for foreign securities in accordance with the Exemption.
Please also note that:
- SumRidge is not registered as a dealer in any Canadian province or territory;
- The jurisdiction of SumRidge’s head office or principal place of business is in the State of New Jersey, United States of America;
- All or substantially all of SumRidge’s assets may be situated outside of Canada;
- There may be difficulty enforcing legal rights against SumRidge because of the above; and
- The name and address of the agent for service of process of SumRidge in each of the local jurisdictions are listed below.
- Please see below the names and addresses of the agents for service of process of SumRidge in Canada:
SYSTÈME CORPORATIF CT (CANADA) LTÉE a/s Joli-Coeur Lacasse s.e.n.c.r.l
1134, Grande Allée Ouest, Bureau 600
Québec (Québec) G1S 1E5
“Permitted Client” means any of the following:
(a)a Canadian financial institution or a Schedule III bank;
(b)the Business Development Bank of Canada incorporated under the Business Development Bank of Canada Act (Canada);
(c)a subsidiary of any person or company referred to in paragraph (a) or (b), if the person or company owns all of the voting securities of the subsidiary, except the voting securities required by law to be owned by directors of the subsidiary;
(d)a person or company registered under the securities legislation of a jurisdiction of Canada as an adviser, investment dealer, mutual fund dealer or exempt market dealer;
(e)a pension fund that is regulated by either the federal Office of the Superintendent of Financial Institutions or a pension commission or similar regulatory authority of a jurisdiction of Canada or a wholly-owned subsidiary of such a pension fund;
(f)an entity organized in a foreign jurisdiction that is analogous to any of the entities referred to in paragraphs (a) to (e);
(g)the Government of Canada or a jurisdiction of Canada, or any Crown corporation, agency or wholly-owned entity of the Government of Canada or a jurisdiction of Canada;
(h)any national, federal, state, provincial, territorial or municipal government of or in any foreign jurisdiction, or any agency of that government;
(i)a municipality, public board or commission in Canada and a metropolitan community, school board, the Comité de gestion de la taxe scolaire de l’île de Montréal or an intermunicipal management board in Québec;
(j)a trust company or trust corporation registered or authorized to carry on business under the Trust and Loan Companies Act (Canada) or under comparable legislation in a jurisdiction of Canada or a foreign jurisdiction, acting on behalf of a managed account managed by the trust company or trust corporation, as the case may be;
(k)a person or company acting on behalf of a managed account managed by the person or company, if the person or company is registered or authorized to carry on business as an adviser or the equivalent under the securities legislation of a jurisdiction of Canada or a foreign jurisdiction;
(l)an investment fund if one or both of the following apply:
- the fund is managed by a person or company registered as an investment fund manager under the securities legislation of a jurisdiction of Canada;
- the fund is advised by a person or company authorized to act as an adviser under the securities legislation of a jurisdiction of Canada;
(m)in respect of a dealer, a registered charity under the Income Tax Act (Canada) that obtains advice on the securities to be traded from an eligibility adviser, as defined in section 1.1 of National Instrument 45-106 Prospectus Exemptions, or an adviser registered under the securities legislation of the jurisdiction of the registered charity;
(n)in respect of an adviser, a registered charity under the Income Tax Act (Canada) that is advised by an eligibility adviser, as defined in section 1.1 of National Instrument 45-106 Prospectus Exemptions, or an adviser registered under the securities legislation of the jurisdiction of the registered charity;
(o)an individual who beneficially owns financial assets, as defined in section 1.1 of National Instrument 45-106 Prospectus Exemptions, having an aggregate realizable value that, before taxes but net of any related liabilities, exceeds $5 million;
(p)a person or company that is entirely owned by an individual or individuals referred to in paragraph (o), who holds the beneficial ownership interest in the person or company directly or through a trust, the trustee of which is a trust company or trust corporation registered or authorized to carry on business under the Trust and Loan Companies Act (Canada) or under comparable legislation in a jurisdiction of Canada or a foreign jurisdiction;
(q)a person or company, other than an individual or an investment fund, that has net assets of at least $25 million as shown on its most recently prepared financial statements;
(r)a person or company that distributes securities of its own issue in Canada only to persons or companies referred to in paragraphs (a) to (q);