The material provided on this website is for informational purposes only; it is not guaranteed as to its accuracy, although a reasonable effort is made to ensure accuracy and information is gathered from sources we deem reliable.
Client account access is provided by Hilltop Securities (SWST) and is subject to SWST’s system availability.
Member of SIPC, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at www.sipc.org.
Regulation Best Interest
Click here for access to our Customer Relationship Summary and further disclosures relative to Regulation Best Interest.
WHAT DOES WHITE MOUNTAIN CAPITAL, LLC
DO WITH YOUR PERSONAL INFORMATION?
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.|
The types of personal information we collect and share depend on the product or service you have
with us. This information can include:
Social Security number and Government-issued ID numbers
Date of Birth and Residential & Employment Data
Transaction History and Financial Data and other data
|How?||All financial companies need to share clients' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients' personal information; the reasons White Mountain Capital chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does White Mountain Capital, LLC share?||Can you limit this sharing?|
|For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus||YES||NO|
|For our marketing purposes - to offer our products and services to you||NO||N/A|
|For joint marketing with other financial companies||NO||N/A|
|For our affiliates' everyday business purposes - information about your transactions and experiences||YES||NO|
|For our affiliates' everyday business purposes - information about your creditworthiness||YES||YES|
|For nonaffiliates to market to you||NO||N/A|
|To limit our sharing||
If you are a new customer, we can begin sharing your information 3 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.
|Who we are|
|Who is providing this notice?||White Mountain Capital, LLC|
|What we do|
|How does White Mountain Capital protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.|
|How does White Mountain Capital collect my personal information?||
We collect your personal information, for example, when
open an account or make changes to your profile
make a trade or request information on a product or service
complete applications, among other times
|Why can't I limit all sharing?||
Federal law gives you the right to limit only:
sharing for affiliates' everyday business purposes - information about your creditworthiness
affiliates from using your information to market to you
sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing.
|What happens when I limit sharing for an account I hold jointly with someone else?||Sharing on the entire account is limited.|
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.|
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.|
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.|
|Other important information|
|As an introducing broker, White Mountain Capital will share your personal information with our clearing firm, Hilltop Securities Inc (SWST). SWST handles transaction processing, clearing and custody and provides statements and confirmations.|
Under the USA PATRIOT Act and other regulations, White Mountain Capital must establish a compliance program, which includes policies and procedures to detect and report suspicious transactions to the government, as well as ensure compliance with the laws. White Mountain Capital must also implement specialized employee training programs, designate an anti-money laundering compliance officer and conduct independent testing of the effectiveness of the program. White Mountain Capital has appointed an anti-money laundering officer to direct the program. All of our employees are trained in anti-money laundering practices and procedures and the details of the firm's policies.
The regulations have also imposed new requirements on client information and verification of that information. White Mountain Capital is required to verify the identity of the clients with whom they do business, determine the source of funds in a client's account and obtain the information about a client's financial status. As part of our compliance with these new regulations and in support of the fight against money laundering around the world, we may ask clients for additional information and documentation about certain accounts and transactions. This information may be used to verify client identity.
If you have any questions regarding our anti-money laundering program, please contact your Account Executive.
White Mountain Capital has developed a Business Continuity Plan to provide procedures for response and recovery in the event of a significant business disruption. The purpose of the plan is to identify responsible personnel in the event of a local or regional disaster, natural or otherwise; safeguard employee lives and firm property; evaluate the situation and initiate appropriate action; recover and resume operations to allow continuation of business; provide customers with access to their funds and securities; and protect books and records. The Plan was developed considering the types of business conducted, systems critical to support business, and geographic dispersion of offices and personnel.
The Plan is designed for implementation to continue conducting business in the event of a disaster that results in a significant business disruption. Whether all or only parts of the Plan are implemented depends on the nature of the disruption. Generally, a significant business disruption would include:
A localized disruption in White Mountain Capital’s office or city would result in a shorter outage than a major regional or national event (e.g., hurricane, widespread power outage or terrorism). In all cases, resumption of business is anticipated within the same business day. White Mountain Capital has made arrangements to safeguard its books and records in the event of a disaster. Should we need to move our operations to an alternate location, we will notify you through our website (www.whitemountaincapital.com) and/or outgoing message on 212-509-0313, our firm’s phone number, how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to their funds and securities.
White Mountain Capital’s clearing agent maintains customer confirmations and statements under the terms of the clearing agreement. Hilltop Securities Inc (SWST) has developed a disaster and recovery plan to recover and retrieve its records lost in a disaster, including backing up its important records in a geographically separate area.
White Mountain Capital has received assurance from its clearing agent (SWST) that SWST’s business continuity plan is consistent with self-regulatory organization rule requirements and provides adequate protection of customer funds and securities held on behalf of White Mountain Capital’s customers. White Mountain Capital’s senior management will review the clearing firm plan or a summary of its plan at least annually or whenever its plan is changed.
The Securities and Exchange Commission has adopted two rules to enhance the visibility of execution quality of the U.S. securities markets for public investors.
SEC Rule 605 (Formerly SEC Rule 11Ac1-5) - Disclosure of Order Execution Information
Rule 11 Ac1-5 requires that White Mountain Capital, LLC publicly disclose, on a monthly basis, basic standardized information concerning its handling and execution of orders.
Introducing Broker Agreement
White Mountain Capital maintains an introducing clearing agreement with Hilltop Securities Inc (SWST).
White Mountain Capital, LLC does not receive compensation for directing order flow.
SEC Rule 606 (Formerly SEC Rule 11Ac1-6) Disclosure of Order Routing Information
Under SEC Rule 606 (formerly SEC Rule 11Ac1-6), White Mountain Capital, a broker dealer that routes customer orders in equity and option securities, is required to make publicly available quarterly reports that identify the market centers to which customer orders are routed for execution. In addition, White Mountain Capital is required to disclose to its customers, upon request, the markets to which their individual orders were routed.
Click on the link below for execution statistics for the most recent quarter.
Rule 606 Report
To File a Complaint
Customer complaints can be addressed to the following:
White Mountain Capital, LLC
352 7th Ave, Suite 702
New York, NY 10001
Or by phone: 212-509-0313