Clearpool Disclosure Statement

Please find our US privacy policy here.

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. What this means for you: When you open an account with CES, we will ask for your name, address, and any other information that will allow us to identify you. We may also ask to see other identifying documents.

CES is required by the SEC to disclose to new customers, and annually to all customers, its policies regarding the practice of receiving “payment for order flow”. The SEC defines “payment for order flow” to include any cash or non-cash compensation received by a broker or dealer from another broker or dealer, national securities exchange, registered securities association or exchange member in exchange for sending customer orders to such entities for execution. CES does receive payment for order flow.

CES is not responsible for any performance or communication issues relating to any third party technology including but not limited to order management or portfolio management systems.

To file a complaint regarding Clearpool Execution Services, LLC (“CES”), employee of CES, or services provided to you by CES contact:

Compliance
Clearpool Execution Services, LLC
17 State Street, 38th Floor
New York, NY 10004
212-531-8518

FINRA requires that CES, as a member firm, notify our customers about the availability of information through the FINRA Broker Check program. To obtain a brochure or to log onto FINRA Broker Check you may use the following information: the FINRA Broker Check Hotline Number is 1-800-289-9999; the FINRA Web Site address is www.finra.org.

CES, as a member of SIPC and pursuant to FINRA Rule 2266, discloses to new customers, and annually to all customers, that they may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at the following address:

Securities Investor Protection Corporation 805 Fifteenth Street NW, Suite 800
Washington, DC 20005-2215
Tel. (202) 371-8300
Web Site: http://www.sipc.org/

Summary Disclosure Statement for Clearpool Execution Services, LLC. pursuant to FINRA regulations

(Pursuant to the Financial Industry Regulatory Authority (FINRA) regulations under Rule 4370)

Since September 11, 2001, the financial community continues to develop new processes, procedures and regulations to improve the resiliency of the financial markets, provide clearer security for customers’ assets and reaffirm confidence in the ability to mitigate and/or respond to momentous events.

All members of Self-Regulatory Organizations (SRO’s) such as NASD and NYSE are required through FINRA to have a Business Continuity Plan in place and to communicate that information to their customers. Clearpool Execution Services, LLC . has taken appropriate steps to protect our customers’ assets and to comply with all financial market rules and regulations.

Clearpool Execution Services, LLC aligns with BMO Financial Group in maintaining business continuity preparedness by developing, testing, and exercising viable recovery strategies and plans. Our Business Continuity Management Program continues to evaluate the threats to our respective business and build upon our strategy to mitigate those threats. Our program incorporates industry sound practices and complies with regulatory guidance applicable to BMO Financial Corp.

Clearpool Execution Services, LLC Business Continuity objectives include the ability to safeguard the interests and well-being of our clients, customers, and employees in the event of any type of emergency, business disruption, or other unforeseen circumstances. We have established a framework that facilitates the rapid recovery and timely resumption of critical operations following any disruption to business. Our comprehensive business continuity strategy is designed so that critical processes and contracted third party arrangements are effective and compatible.

The Continuity Plan is reviewed and tested annually and has been approved by senior management. Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternative physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting. We constantly re-evaluate and improve our response to disruptive events, therefore the CES Business Continuity Plan is subject to modification without notification.

Should a catastrophic event cause both the main and back-up facilities of Clearpool Execution Services, LLC to be inoperable or inaccessible, our Toronto based, investment banking affiliate within BMO Financial Group, would be capable of fulfilling our broker/dealer role in the administration, safekeeping and processing of Clearpool Execution Services, LLC .’s customers’ assets.

If you have questions about our business continuity planning, you can contact our Compliance Officer:
Name: Michael Forlenza | Phone: +1-212-702-1981

Please find our annual disclosure statement here.

Please find our Canadian privacy policy here.

Clearpool and/or its affiliates maintain this website to provide you with information about the products and services of various members of BMO Financial Group. Each time you use this website you indicate your acknowledgment and acceptance of the terms and conditions below, which we may revise periodically without notice. If you do not accept these terms and conditions, do not use the website.

Use of Information

The information contained on this website and pages within is for informational purposes only and is not intended to provide specific legal, accounting, financial or tax advice for you and should not be relied upon in that regard.

Email

Please note that regular, unencrypted e-mail messages over the Internet are not secure (i.e. not private) at this time. Please do not send personal or financial information to us using unencrypted e-mail. Alternative, secure means of communicating with us over the Internet are available to Online Banking customers. We are not liable if you send confidential information to us over the Internet using regular, unencrypted e-mail and that information subsequently becomes public through no fault of ours.

No Solicitation

Nothing on this website constitutes a solicitation, recommendation or offer by Clearpool or its affiliates to buy or sell products or services of any kind whatsoever including without limitation securities or any other financial instrument of any issuer.

No Advice

The financial market data, including quotes, charts and news are provided by various information suppliers that are independent of Clearpool and its affiliates. The information provided on this website is intended for informational purposes only and is not intended to constitute financial, accounting, legal or tax advice. Many factors unknown to us may affect the applicability of any statement or comment that we make on our website to your particular circumstances. You should consult directly with a professional from Clearpool and/or its affiliates as well as your other advisers before acting on any information on this website.

Applicable Jurisdiction

The information on this website is intended for use by persons resident in Canada only. Any products or services mentioned on this website are made available only in accordance with local law (including applicable securities laws) and only where they may be lawfully offered for sale.

U.S. Residents

The information is not intended to be construed as an offer to sell or a solicitation to buy or sell any products or services of any kind whatsoever including without limitation securities or any other financial instrument in the United States of America or the territories or possessions thereof.

Hyperlinks are Not Endorsements

Links from this Website to other Websites, or references to products, services or publications other than those of Clearpool and/or its affiliates and its subsidiaries and affiliates, do not imply the endorsement or approval of such Websites, products, services or publications by Clearpool or its affiliates.

Copyright

Unauthorized use of the logos and/or name, trade names or trade-marks or trade names of Clearpool or its affiliates is prohibited. All information at this site is protected under the copyright laws of Canada and in other countries. In addition, certain information may be copyrighted by others. Unless otherwise specified, no one has permission to copy, redistribute, reproduce or republish in any form, any information found at this Website. If you wish to incorporate the Clearpool name or trade names, or our products names within another site, please contact us for permission.

Disclaimer of Warranty and Limitation of Liability

CLEARPOOL AND/OR ITS AFFILIATES DO NOT WARRANT THE ACCURACY, COMPLETENESS, QUALITY, ADEQUACY OR CONTENT OF ANY INFORMATION OR TOOL ON THIS WEBSITE NOR DOES IT MAKE ANY WARRANTY AS TO THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE.

SUCH INFORMATION OR TOOL IS PROVIDED “AS IS” WITHOUT WARRANTY OR CONDITION OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, THE IMPLIED CONDITIONS AND WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE MAY NOT APPLY TO YOU.

CLEARPOOL AND/OR ITS AFFILIATES WILL NOT BE RESPONSIBLE OR LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, OR ANY OTHER DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, LOST REVENUES, LOST PROFITS OR LOSS OF PROSPECTIVE ECONOMIC ADVANTAGE, RESULTING FROM THE USE OR MISUSE OF THIS WEBSITE, OR THE INFORMATION, DOCUMENTS, SOFTWARE OR CONTENT THEREOF, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR SUCH DAMAGES ARE REASONABLY FORESEEABLE.

If you have a complaint regarding misconduct on the part of any employee of Clearpool Execution Services (Canada) Limited. (“Clearpool”), please make a written complaint to our Designated Complaints Officer (“DCO”) at the address below.  You may also make a verbal complaint.  An acknowledgment will be sent within 5 days of receiving the complaint.  Within 90 days, a substantive response letter outlining Clearpool’s response to your complaint will be sent.  In some circumstances, it may take longer than 90 days to respond.  If this is the case, we will advise you of the delay, the reasons why and a new expected response date.

You may contact the DCO at any time during this process to get an update on the status of your complaint.  Contact the Chief Compliance Officer at:

First Canadian Place
100 King Street West
3rd Floor
M5X 1A1

Clearpool Execution Services (Canada) Limited is a member of the Canadian Investor Protection Fund and of the Investment Industry Regulatory Organization of Canada Inc. The contents of the Clearpool website are not intended, and should not be construed, as a solicitation of customers or business in any jurisdiction in which Clearpool is not registered as a dealer in securities.