Lombard Securities Privacy Disclosure

Pursuant to federal regulations Lombard Securities Incorporated (“LSI”) has established the following policies with respect to the disclosure of nonpublic, personal information obtained in connection with your opening and maintaining an account with LSI:

(i) Any information disclosed on a Customer Account Application Agreement, Margin Agreement, Option Account Application, IRA Application, or any other papers required, or requested, in connection with the opening of an account with LSI, and any periodic statements of account activity, and trade confirmations, are covered by these policies.

(ii) Such information may be disclosed to administrative and operational employees of LSI for the purposes of permitting them to service your accounts and process your transactions, as well as to your registered representative and his/her administrative staff.

(iii) Such information may be disclosed to any of LSI’s affiliates, including Lombard Agency, Inc., and Lombard Advisers Incorporated.

(iv) Such information will be disclosed to LSI’s correspondent, Hilltop Securities, Inc. (“SWS”), and to the money market fund provider in connection with your opening a money market sweep account, or to a non-affiliated investment adviser providing WRAP account services, and members of their staffs, for the purpose of servicing your account.

(v) Such information, including account numbers, shall not be disclosed by LSI to other non-affiliates of LSI, except under the foregoing circumstances:

(A) Upon the receipt of written request or authorization to do so, signed by you, the
customer(s); or,

(B) In connection with an examination of LSI’s books and records by a regulatory
organization established under federal or state laws; or,

(C) Pursuant to a subpoena issued by a court or arbitration of competent
jurisdiction; or,

(D) In connection with the submission of an application, signed by you, to
purchase an insurance product or mutual fund product.

(vi) Such information shall be maintained in both hard-copy and electronic format, and shall be accessible to the staff members of LSI, your registered representative, and to staff members of SWS , and our money market provider, or their agents. Hard copy documents are not available to non-associated persons, and electronic format is secured by firewalls requiring authorized password(s) to access.

(vii) Opt Out Provisions: You do have the right to prevent the disclosure of non-public personal information to non affiliated third parties – commonly referred to as the right to “opt out”. However, this opt out provision does not apply in cases where the information sharing is necessary to provide consolidated statements of account activity, complete a transaction, or service your account, nor does it apply to information disclosed to market products or services offered through joint agreements with another financial institution, e.g., SWS, our money market fund provider, and investment advisers with whom Lombard Advisers Incorporated has WRAP fee arrangements. Should you not wish disclosures be made to any of the foregoing financial institutions, or to affiliates of LSI, or, should you be unable to accept any of the disclosure exceptions specified in Section (v) above, you must notify the firm’s Customer Service Department immediately, so that your account may be closed in that LSI would not be able to service your account under such circumstances.

Lombard Securities Incorporated Customer Service
Fax: 410.732.0303
Hilltop Securities, Inc.


Hilltop Securities Inc. Privacy Policy

At Hilltop Securities Inc. (HTS), we are committed to protecting your privacy and the confidentiality of your personal and financial information. The measures we take to keep your personal information private and secure are outlined below.

HTS has multiple affiliates, including Hilltop Securities Independent Network Inc., Southwest Insurance Agency, Inc., First Southwest Asset Management, LLC, National Lloyds Insurance Company, and PlainsCapital Bank. These companies, along with HTS Inc., are wholly owned subsidiaries of Hilltop Holdings Inc., a financial holding company whose stock is listed on the New York Stock Exchange under the ticker symbol HTH. Since the affiliates are all part of one corporate family, they work with one another and may work together to service your financial needs. The sharing of your information among our affiliates enables us to serve you more efficiently and makes it more convenient for you to do business with us. We are permitted by law to share information with our affiliates about your account history and your experiences with us. All of our affiliates follow similar privacy policies.

How We Protect Confidentiality

HTS uses procedural, physical and electronic system safeguards to store and secure information about you in compliance with federal standards. Our systems protect your information from unauthorized access, alteration, and destruction. Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities.

When we enter into agreements with other companies to provide services to us or to make products and services available to you, we include a confidentiality clause. Under such an agreement, these companies may receive information about you, but they may only use it for the intended purpose – to benefit you.

Persons Covered by the Privacy Policy

The HTS Privacy Policy applies to anyone who is a current or former HTS brokerage or investment advisory client or who registers with one of our services or promotional offers. We provide you with a copy of this policy when you open an account, and we send you annual notifications thereafter. If we change our policy regarding the sharing of information, we will notify you in advance and give you the opportunity to “opt out” of such disclosure.

How We Obtain Information About You

In the normal course of business, we collect, retain and use information about you to serve your financial needs, administer your account(s) and inform you of products and services that may be of interest. This data, known as non-public personal information, may be collected from several sources, including: applications and other forms you file with us (e.g., name, assets, income), records of transactions with us, our affiliates, non-affiliated third parties and others (e.g., credit report). Because we strive to provide you with the best possible service, the accuracy and completeness of your personal information is important to us. We ask that you review your information regularly to ensure that it is correct. Please contact your financial advisor or HTS directly if you need to correct or update your personal information.

Sharing Information-With Whom and Why

HTS does not sell your personal information to anyone. We restrict the types of information we share and the types of entities with whom we share it. The primary reason for sharing information about you is to increase your convenience in transacting business with us and to give you more financial service choices.

We do not disclose your personal information to non-affiliated third parties, unless one of the following exceptions applies: (1) We disclose personal information to service providers that assist us in processing your transactions or servicing your account(s). An example would be the company that prints and mails your account statement. (2) We disclose or report personal information in limited circumstances when we believe in good faith that disclosure is required or permitted under law. For example, we would provide information in cooperation with securities regulators or law enforcement authorities, to resolve consumer disputes, or to perform credit evaluations and authenticate checks.

Internet Security

We do not retrieve account or personal information from visitors who browse the public areas of our website.

Clients who have the ability to access their accounts online are required to log on to our secure websites with their user name and individually selected password. Your password is known solely to you and should never be shared with anyone.  Each time you access your account, please log off when you are finished.  This will prevent someone else from accessing your account if you leave your computer unattended.

HTS employees use information about you to respond to your needs and to provide you with information about specific products in which you may have an interest. We instruct our employees to use strict standards of care in handling the personal, confidential information of customers and remind them on a regular basis of their obligations with regard to the confidentiality of customer information.

Option to Opt Out and Change Notices

If for any reason at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to opt out of such disclosure. For your reference, this Privacy Policy has been posted at www.hilltopsecurities.com. If you have questions or concerns, please contact us via email at info@hilltopsecurities.com.

Revised 01/25/2016


Terms of Use / Website Disclaimer

This Web site is offered to you, the user, conditioned on your acceptance without modification of the terms, conditions and notices contained herein. Your use of this Web site constitutes your agreement to all such terms, conditions and notices. Lombard Securities Inc. may at any time change or modify the terms and conditions applicable to your use of this Web site, or to any aspect or feature of the Web site itself.

The information provided in this Web site is intended for your personal and non-commercial use. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, products or services obtained from this Web site.
Neither Lombard Securities Inc., and/or its affiliates, information providers nor content providers shall have any liability to you or third parties for the accuracy, completeness, timeliness or correct sequencing of information available on this Web site, or for any decision made or action taken by you in reliance upon such information, or for the delay or interruption of such information.

You should always consult your stock broker or other authorized financial advisor or representative to establish actual stock prices before making any stock trades or other financial decisions. Lombard Securities Inc., its affiliates, information providers and content providers shall have no liability for investment decisions or other actions taken or made by you based on the information provided on this Web site.

The information available on this Web site is provided on an “as is” basis without warranties of any kind, either express or implied, including (but not limited to) warranties of merchantability or fitness for a particular purpose, title or non-infringement. In no event will Lombard Securities Inc., its affiliates, information providers or content providers be liable to you or any third party for any direct, indirect, consequential, incidental, punitive or special damages (including but not limited to lost profits) arising out of or in any way connected with the use of this Web site, or with the delay or inability to use this Web site, or for any information, products or services obtained through this Web site, whether based in contract, tort, strict liability, or otherwise, even if Lombard Securities Inc., its affiliates, information providers and/or content providers has been advised of the possibilities of damages.

Some states do not allow certain limitations on implied warranties, or the exclusion or limitation of incidental, consequential or other damages, so that these disclaimers and limitations may not apply to you.

The information provided is intended for U.S. residents only.


Business Continuity Plan

This page provides our clients, and the public, with a summary of Lombard Securities’ Business Continuity Plan in accordance with FINRA regulations. While no summary can fully anticipate each and every business interruption contingency, we will attempt to present an overview of our contingency planning. Lombard’s goal is to resume operations as quickly as possible in the event of a significant business disruption.

Lombard’s plan anticipates two kinds of significant business disruptions: those which are external, such as a terrorist attack or other regional or national disruption that could prevent the operation of some or all of the securities markets and which could affect the performance of a substantial number of businesses, and those which are internal, which would affect only Lombard’s ability to communicate and do business, such as a flood or fire directly affecting the firm’s main office.

Since Lombard is a fully disclosed broker-dealer, it does not hold customer funds or securities, and does not execute securities transactions. Lombard accepts and enters orders on behalf of its clients into a computer system that is hosted and maintained by Lombard’s correspondent firm, Southwest Securities, Inc., a New York Stock Exchange Member. Our reaction to any external event, therefore, would be highly dependent upon whether the event, or events, also affected the operations of our correspondent clearing firm. Our correspondent (Hilltop Securities, Inc.) has its own Business Continuity Plan.

In the event of an internal disruption, Lombard employees will work from their residences or from the residence of one of the firm’s executive officers, or from our suburban Baltimore office in Towson, MD, depending on their function. If phone service is unavailable in the area of the main office, we anticipate that the firm’s brokers would still be able to use the Internet based computer system of our correspondent, or its 800 telephone number, to enter orders and carry out other instructions of customers. In the event that our correspondent’s computer system is down or not in service, a direct customer service telephone line is available for brokers to enter orders and make account information inquiries.

Lombard maintains most of its hard copy and electronic books and records at its main office at 1820 Lancaster Street, Baltimore, Maryland. Transaction-based records and client account information is located on both our correspondent’s computer system and in hard copy at Lombard’s offices. Customer account information is also maintained in Lombard’s field offices. In the event of an internal business disruption affecting Lombard’s main office, the firm’s employees will use available resources of our clearing firm to service customers.

This summary provides only an overview of a generally more detailed response to various significant business disruption events. Due to the inherent uncertainties involved, there can be no assurance given as to whether Lombard’s efforts would be successful.

Please check this page for updates of our Business Continuity Plan summary.