FINRA Rule 2266 and NYSE Rule 409A

Moorgate Securities, LLC ("MSL" or the "Firm") is a member of the Securities Investor Protection Corporation (“SIPC”). FINRA Rule 2266 and NYSE Rule 409A require MSL to disclose SIPC Contact Information. SIPC plays an important role in the overall system of investor protection in the United States by, in certain specified situations, restoring funds to investors with assets in the hands of bankrupt and otherwise financially troubled brokerage firms. When a brokerage firm is closed due to bankruptcy or other financial difficulties and customer assets are missing, SIPC steps in as quickly as possible and, within certain limits, works to return customers’ cash, stock, and other securities. You may obtain more information about SIPC, including a brochure entitled How SIPC Protects You, by contacting SIPC at:

Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215
Phone: (202) 371-8300
Email: asksipc@sipc.org
You may also visit SIPC’s website at www.sipc.org.

FINRA Regulation Public Disclosure Program

MSL is required by FINRA Rules to provide you with information about the availability of information through FINRA’s Public Disclosure Program. The investor brochure may be obtained via the FINRA Web Site (www.finra.org) or through the FINRA Public Disclosure Program Hotline Number at (800) 289-9999.

Important Information about New Account Opening Procedures / Customer Identification Program (CIP)

The USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) was enacted to strengthen the United States government’s ability to combat terrorist financing and money laundering. An essential component of the USA PATRIOT Act requires financial institutions to obtain, verify and record information that identifies each person or entity with an account relationship at a financial institution.

If you are an individual and wish to open an account or have an account currently with MSL, carry out transactions with MSL, or receive formal communications from MSL, MSL will collect the following information about you:

  • Name,

  • Date of birth,

  • Address,

  • Identification number:

    • U.S. citizen: taxpayer identification number (Social Security number or employer identification number), or

    • 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.

If you are a corporation, partnership, trust or other entity that wishes to open an account or has an account currently with MSL, carries out transactions with MSL, or receives formal communications from MSL, then MSL will collect the following information about you:

  • Name,

  • Street address (either principal place of business, a local office or other physical location),

  • a U.S. taxpayer identification number, or if not organized or a resident in the United States or filing U.S. income tax returns, the number and country of issuance of any other government-issued document certifying the existence of the organization, and

  • such other information or documents that we consider necessary to verify the entity’s identity (examples of additional information include articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument. We may also verify the entity’s identity through other means).

If the above information is not provided, MSL may not be able to open an account for you, maintain an account for you, carry out transactions for you, or distribute formal communication to you.  If MSL has already opened an account for you, such account may need to be closed if the above information is not complete.

Business Continuity Planning

MSL has an established Business Continuity Plan (“BCP”) that includes systems and procedures for backup and recovery of mission critical systems / data, alternate communications with customers / employees and alternate physical locations. MSL’s BCP is designed to address the effects of various significant business disruptions (“SBDs”), whether internal (e.g., affecting a MSL building) or external (e.g., affecting a business district, city or region in which MSL conducts business), that may be caused by a number of foreseeable scenarios. MSL’s BCP includes a crisis management framework as well as a contingency site and plans to address both internal and external SBDs.  All MSL’s operational facilities are equipped for resumption of business. Regarding all circumstances within our control, MSL’s recovery time objective for business resumption is within six (6) hours, depending upon the availability of external resources.

MSL’s policy is to respond to all SBDs by focusing on:

  • Safeguarding employees’ lives.

  • Safeguarding customer assets.

  • Safeguarding MSL’s property.

  • Making timely and prudent financial and operational assessments.

  • Quickly recovering and resuming essential business operations within hours, and if not feasible, the next business day.

  • Protecting MSL’s books and records, and

  • Allowing MSL’s customers to transact business.

If you would like a copy of the full plan, please contact:

Moorgate Capital Partners, LLC
Attn: Legal and Compliance Department
1686 Union Street, Suite 307
San Francisco, CA 94123
(415) 678-5116

Complaints 

Complaints concerning services provided by MSL may be directed to:

Moorgate Capital Partners, LLC
Attn: Legal and Compliance Department
1686 Union Street, Suite 307
San Francisco, CA 94123
(415) 678-5116

Confidentiality 

MSL’s policy is to maintain the confidentiality of client order and transaction information. Please be assured that MSL has strict policies and procedures in place on confidentiality of client information, as well as, sophisticated and secure operational technology to provide superior protection of our clients’ information.

MSL’s Privacy Policy

The Gramm-Leach Bliley Act and SEC Regulation S-P and Regulation SAM require MSL to disclose its privacy policy.

Types of Nonpublic Personal Information We Collect:

We collect nonpublic personal information about you that is either provided to us by you or has previously been provided to one of our affiliates by you, or obtained by us with your authorization.

Parties to Whom We Disclose Information:

For current and former clients, we do not disclose any nonpublic personal information obtained in the course of our business or from our affiliates except as required or permitted by applicable law, rule or regulation. Permitted disclosures include, for instance, providing information to our employees and, in limited situations, to unrelated third parties who need to know that information to assist us in providing services to you.  In all such situations, we stress the confidential nature of information being shared. MSL may also share information with its affiliates.

Protecting the Confidentiality and Security of Current and Former Client’s Information:

We retain records relating to services that we provide so that we are better able to assist you with your needs and in some cases, to comply with professional guidelines or applicable law, rule or regulation. In order to guard your nonpublic personal information, we maintain physical, electronic and procedural safeguards that comply with our professional standards.

Should you wish to opt out of our information sharing, or have any other questions about this communication, please contact:

Moorgate Capital Partners, LLC
Attn: Legal and Compliance Department
1686 Union Street, Suite 307
San Francisco, CA 94123
(415) 678-5116