FINRA Rule 2124 (Net Trading)
At Puma Capital, LLC (“PUMA” or “Firm”), we give the highest priority to seeking the best quality execution of customer orders, taking into consideration all of our customer’s specific needs. This letter is being provided to you to clarify certain terms and conditions governing the execution of your orders in equity securities that are handled by PUMA.
Orders received by Puma Capital that are “not held” are not subject to the SEC Order Handling Rules. PUMA may execute certain “not held” orders on a net basis. Additionally, trades may be confirmed at an average price when multiple executions are required to complete the “not held” order. Trades will be executed on a net basis with the following understanding:
A “net” transaction is one in which we, after having received your order to buy (sell) a security, buy (sell) the security at one price from (to) another party and then sell to (buy from) you at a different price, with the difference representing the firm’s compensation for executing the transaction.
If the preceding statement is not consistent with your desire for PUMA executing certain orders on a net basis, please notify PUMA Sales/Traders at the time you place your order that you do not wish for your order to be transacted on a “net” basis, or you may email firstname.lastname@example.org. If you do not object, PUMA may reasonably conclude that you have consented to trading on a “net” basis pursuant to FINRA Rule 2124.
Customer Identification Program
To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.
When you open an account, Puma Capital, LLC is required to collect the following information:
Date of birth
• U.S. citizen: taxpayer identification number (Social Security number or employer identification number)
• Non-U.S. citizen: taxpayer identification number; passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you.
You may also need to show 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.
U.S. Department of the Treasury, Securities and Exchange Commission, and FINRA rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance.
If you don’t provide the information requested or your identity can’t be verified Puma Capital may not be able to open an account or carry out transactions for you. If Puma Capital has already opened an account for you, we may have to close it.
Puma Capital, 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 are 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.
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.
Our clearing firm, Broadcort Correspondent Clearing Division of MLPF&S, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments within one business day. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions – Significant business disruptions can vary in scopes, such as only our firm, a single building housing our firm, the business district where our firm is 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 will transfer our operations to one of our other fully redundant sites when needed and expect to continue business without interruption. In a disruption affecting our business district, city, or region, we will transfer our operations to one of our other fully redundant sites when needed and expect to continue business without interruption. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website www.pumacap.com or our customer emergency number, (212) 269-4100 how to 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.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (212) 269-4100 or email@example.com, you should call our alternative number (732) 479-0550 or go to our website at www.pumacap.com. If you cannot access us through either of those means, you should contact our clearing firm, Broadcort Correspondent Clearing Division of MLPF&S, at (646) 743-0775 for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.