^

Regulation Best Interest

SEC rules require broker-dealers and all associated persons to act in a customer’s best interest when making a recommendation to a retail customer. An important component of Regulation Best Interest is the Customer Relationship Summary, which provides an overview of how White Mountain Capital will service your account, what you should expect to pay and other essential information, including disclosures and conflicts.


Form CRS Customer Relationship Summary
Supplemental Disclosures
Commissions and Fee Schedule

White Mountain Capital, LLC
Form CRS Customer Relationship Summary May 2020


Is A Brokerage Account Right For You?

There are different ways you can get help with your investments. You should carefully consider which types of accounts and services are right for you. White Mountain Capital is a broker-dealer registered with the Securities and Exchange Commission and provides brokerage account and services rather than advisory account services. This document gives you a summary of the types of services we provide and how you pay.

Please ask us for more information. There are some suggested questions at the end of this document. You can also get more information about White Mountain Capital and its financial professionals, as well as use free tools to research investing and financial instruments at www.Investor.gov/CRS, www.finra.org and www.sipc.org.

WHAT INVESTMENT SERVICES AND ADVICE CAN YOU PROVIDE ME?

RELATIONSHIPS AND SERVICES

OUR OBLIGATIONS TO YOU We must abide by certain laws and regulations when working with you.

For additional information on conflicts, please see our Fee Schedule at www.whitemountaincapital.com/customers-relationship.html#DAC

CONVERSATION STARTERS: Ask your broker

  • Given my financial situation, should I choose a brokerage service? Why or why not?
  • How will you choose investments to recommend to me?
  • What is your relevant experience, including your licenses, education and other qualifications? What do those qualifications mean?
WHAT FEES WILL I PAY?

FEES AND COSTS Fees and costs affect the value of your account over time. Ask your broker to give you personalized information on the fees and costs that you will pay.

For additional information on conflicts, please see our Fee Schedule at www.whitemountaincapital.com/customers-relationship.html#DAC

CONVERSATION STARTERS: Ask your broker

  • Help me understand how fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?
WHAT ARE YOUR LEGAL OBLIGATIONS TO ME WHEN PROVIDING RECOMMENDATIONS? HOW ELSE DOES YOUR FIRM MAKE MONEY AND WHAT CONFLICTS OF INTEREST DO YOU HAVE?

CONFLICTS OF INTEREST We benefit from our recommendations to you. When we provide you with a recommendation we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they affect the recommendations we provide you. Here are some examples to help you understand what this means.

For additional information on conflicts, please see our Fee Schedule at www.whitemountaincapital.com/customers-relationship.html#DAC

CONVERSATION STARTER: Ask your broker

  • How might your conflicts of interest affect me, and how will you address them?
HOW DO YOUR FINANCIAL PROFESSIONALS MAKE MONEY
DO YOU OR YOUR FINANCIAL PROFESSIONALS HAVE LEGAL OR DISCIPLINARY HISTORY?

CONVERSATION STARTER: Ask your broker

  • As a financial professional do you have any disciplinary history? For what kind of conduct?
ADDITIONAL INFORMATION

CCONVERSATION STARTER: Ask your broker

  • Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?


Supplemental Disclosures Pursuant to Regulation BI


White Mountain Capital is a broker-dealer that offers equities, fixed income (municipal and corporate), preferreds, options and mutual funds. We do not offer all types of securities; for example, we do not offer variable annuities or futures, which could be desirable products under certain circumstances. We will not consider products that we cannot offer when making recommendations to you.

As an introducing broker dealer, we rely on agreements with several entities to source securities that do not trade on exchanges. For example, we have selling arrangements with dozens of mutual funds, which is a subset of all such products. Our recommendations will be based upon our reasonable belief of which product best serves your interest, from the securities that are available to us.

We have contracted the services of other broker-dealers for routing and execution of orders. While these broker-dealers are required to comply with SEC and FINRA regulations pertaining to best execution, they may have cost-sharing or rebate agreements with other member firms to which they direct our order flow. White Mountain Capital does not have any cost-sharing or rebate arrangements with other broker-dealers.

Our clearing firm charges you fees for certain services, such as an annual custodial fee for IRAs, an inactivity fee for accounts with no transactions, fees for depositing physical stock certificates or checking privileges. A full list of fees that can be charged are found in our Fee Schedule.

Members of White Mountain Capital’s ownership and management also run an affiliated hedge fund. Potential conflicts include:

White Mountain Capital has procedures in place to ensure that allocations are made to client accounts in a manner that does not favor the fund. There are also procedures that mitigate the potential for crossing securities between the fund and client accounts.

White Mountain Capital staff hold their own brokerage accounts at the firm. There are procedures in place to identify and mitigate potential instances of brokers “trading ahead” or giving priority to their own accounts over those of their customers.

As stated in our Customer Relationship Summary, your broker and the firm makes money whenever you conduct a transaction. Therefore, there is an incentive for brokers to recommend transactions. We have procedures and supervisory review processes that are designed to prevent, identify and mitigate possible instances of excessive trading.

The facts and circumstances surrounding a particular recommendation may present other conflicts and/or necessitate additional disclosures. Such disclosures will be made on a case-by-case basis, directly with the customer to whom the recommendation is made.

FEE SCHEDULE


COMMISSIONS AND FEE SCHEDULE—EFFECTIVE 01/01/2019

Fees are subject to change with prior notification.

Commissions will be charged on a per-transaction basis for equities, fixed income, options, preferreds and warrants. Commissions will be 2% or less than the principal amount of the trade, unless extenuating circumstances make the transaction more costly. Should the commission equal more than 2% of the principal amount, your Account Executive will disclose it to you prior to executing the transaction.

Sales loads will be charged by mutual funds, according to the fund’s prospectus. Your account executive will disclose the amount to you prior to executing a purchase or sale in a mutual fund.

Returned Check, per event $35
Wire transfer (domestic), per event $20
Deposit/Withdrawal at Custodian (DWAC) Actual cost as determined by the transfer agent
DTC deliveries, per position $50
Account Transfer via ACAT system, per account $100
Non-ACATs transfer $150
Certificate handling fee, per issue $50
Legal transfer fee $50
Safekeeping, per issue, per year $15
Exercising warrants or rights $25
Exercising employee stock options $50
Inactive holding and reporting fee, per year $50
Qualified plans $250 primary annaul
IRA annual maintenance $45
IRA termination $50
Vision Checking/Card Fees (by application only)  
Visa Platinum Check Card, annually $50
Returned check/NSF fee, per event $25
Stop payment request, per event $25
Copy of canceled check, per event $10
Voluntary Reorganization $50
Margin base rate 4.99%

Please see Hilltop Securities’ Customer Information Brochure or ask your Account Executive for any other fees that may apply to your specific account.

Questions regarding fees, commissions or markups should be directed to Compliance at 212-509-0313.