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
410.342.1300
800.755.2144
Fax: 410.732.0303
Hilltop Securities, Inc.
214.859.1800
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