Neither NatAlliance Securities, LLC (“Natalliance”), a member of FINRA and SIPC, and a broker-dealer registered with the SEC nor any of its affiliates, makes any representation or warranty regarding the correctness of any information contained herein, or the appropriateness, for any person, of any transaction. The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) only and may contain confidential or privileged information. Any errant transmission is not intended to waive confidentiality or privilege. No representation is made on its accuracy or completeness of the information contained in this electronic message and any attachments. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this e-mail and any attachment(s) is strictly prohibited. Please reply to the sender and immediately destroy all copies of this message and any attachments from your system.
When you invest through a brokerage account, your representative receives a commission for buying or selling securities products. This compensation occurs on a transaction basis. As a result, a brokerage relationship may be best for clients who are seeking a pure buy-and-hold strategy. In addition, through a brokerage relationship, your representative may provide education, research, and information about financial products, but he or she is not obligated to provide ongoing investment advice, which is a duty of an advisor to clients in an advisory relationship. Also unlike an advisory relationship, you may not provide your advisor with discretion to buy and sell securities for you in a brokerage account; instead, you must approve each transaction prior to execution
The commissions you pay will depend on the type and nature of the security purchased or sold in your account. Brokerage accounts also will incur certain account fees. For a list of fees charged by Hilltop Securities, our custodian for brokerage accounts and related services, please see the Correspondent Customer Information Brochure
Fixed Income Client Statement Pricing Disclosure
Unlike equities where prices are usually evaluated based on their daily closing prices, bonds generally do not have a uniform closing price, as a majority trade in over-the-counter (OTC) markets or a negotiated market. Additionally, bond prices are affected by many different factors and, consequently, are often derived using pricing models and/or benchmark indices. These factors include but are not limited to; issuer’s credit rating, order size and other features as well as by valuation methods used by independent pricing services.
Third-party resources may provide comparative prices for evaluation purposes. NatAlliance Securities LLC through a third-party pricing vendor supplies these independent daily bond valuations. Typically, pricing services use proprietary pricing models which may or may not be an accurate representation of actual prices. A continually changing market environment presents additional challenges, which may affect the price of bond valuations and, consequently, make statement prices less reliable indications of at what price certain bonds may be trading.
Actual bond prices are determined by what someone is willing to pay – a bid price reflects the price at which a customer can sell. Consequently, an offer or ask price reflects the price at which a customer can buy. The difference between the two prices is referred to as the price spread. When conditions of significant increases in price volatility, the spreads between bids and asks for bonds can increase to wide levels, making bond valuations even less precise. Bond prices reflected on statements are “best-effort estimates” which can be useful for evaluating a portfolio and establishing an allocation mix. However, they should not be interpreted as actual bid or ask prices.
Clients should carefully review their monthly statements and monitor changes in bond prices. However, investment decisions should not be based solely on statement pricing as it may not be indicative of current market prices. Any investor interested in selling bonds prior to maturity should seek assistance from their financial professional. Additionally, when purchasing a bond, clients can evaluate the pricing they received at http://emma.msrb.org/ and http://finramarkets.morningstar.com/BondCenter/Default.jsp or by contacting your financial representative.
Your Privacy Is Our Policy
Why Do We Collect Personal Information
When you apply for and/or open an account with NAS, we collect personal information about you for various purposes. Certain regulatory requirements mandate that information be collected by us so that we may make proper evaluations with respect to your financial needs. Furthermore, the Patriot Act requires that we collect specific information in an effort to fight money-laundering. For more information regarding the Customer Identification Program and the information that we collect, please see the ‘Customer Identification Program’ tab.
How Do We Protect Your Information
Our Sharing Practices
NAS has never and will not provide your personal and sensitive information to affiliates, subsidiaries and/or non-affiliated third parties unless required by law. We do not wish to reserve the right to disclose, nonpublic personal information to affiliates or non-affiliated third parties, except to non-affiliated parties as authorized by law. Essentially, this means that NAS will treat your private (nonpublic information) in a confidential manner and will not be shared with anyone. “Required by law” may include regulatory investigations which mandate that we provide specific information to investigators for purposes of cooperating with their investigation.
Is Your Information Accurate (For existing customers)?
When you opened your account with NAS, you received a copy of your new account application which contains the information you provided to us. In order to ensure that our customer files are complete and accurate, we invite you to provide us with any updates and/or additions to your personal information.
NatAlliance Securities, LLC
Business Continuity Plan
March 2022 Update
I. Emergency Contact Persons
Our firm’s two emergency contact persons are: Mark Salter at 512-609-1720 or firstname.lastname@example.org and Alex Hendrickson at 212-379-1078 or email@example.com.
The firm will provide FINRA with the contact information for the two emergency contact persons: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile number through the FINRA Contact System (FCS). Mark Salter or his designee will promptly notify FINRA of any change in this information through FCS (but no later than 30 days following the change) and will review, and if necessary update, this information within 17 business days after the end of each calendar year.
II. Firm Policy
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.
Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firms.
Approval and Execution Authority
Mark Salter, CEO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Alex Hendrickson has the authority to execute this BCP.
Plan Location and Access
Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on a disk with a file named “Business Continuity Plan”. One disk will be maintained by the Compliance Department. A second copy will be maintained at the New York office location.
III. Business Description
The Firm’s main business is sales and trading in fixed income securities, including corporate bonds, municipal bonds, government backed securities, and collateralized mortgage obligations. The Firm also engages in the sale of equity securities, primarily to institutional customers.
The Firm is an introducing Firm only. It accepts and enters orders, but it does not hold customer funds or securities. It relies on its clearing firms to compare, allocate, settle, and clear transactions.
The Firm has a contract with one clearing Firm, Hilltop Securities.
Hilltop Securities clears the Firm’s fixed income and equity transactions, and it maintains accounts for the Firm’s customers. Hilltop Securities grants customers access to their accounts and delivers customers’ funds and securities. All equity transactions are conducted on a DVP/RVP basis.
The contact information for Hilltop Securities Inc is:
Hilltop Securities Inc.
1201 Elm Street, Suite 3500
Dallas, TX 75270
Our contacts there are:
Chris Cervantes (primary)
Jonathan Rogers (alternate)
IV. Office Locations
Our Firm has the following registered office locations:
Austin, TX (Main)
NatAlliance’s main office is located 111 Congress Avenue, Suite 800, Austin, TX 78701. Its main telephone number is 512-609-1700. Employees travel to the office by means of mass transit and automobile. This office serves as our home office, and supervisory and administrative functions, such as human resources, accounting, legal, and other executive functions, occur at this location. We also engage in order taking and entry at this location. The office serves as one of the primary areas for operational functions on behalf of the firm.
New York, NY
This office is located at 140 E. 45th St, Suite 32B, New York, NY 10017. Its main telephone number is 212-379-1000. Our employees may travel to that office by means of mass transit and automobile. We engage in order taking and entry at this location.
This office is located at 1013 Toldi Ln, Napa, CA 94558. Its main telephone number is 707-637-4042. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
This office is located at 201 King of Prussia Rd, Ste 650, Radnor, PA 19087. Its main telephone number is 484-590-5159. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
Jersey City, NJ
This office is located at 2nd St #204, Apt 3, Jersey City, NJ 07302. Its main telephone number is 212-379-1008. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
This office is located at 400 Mapleton Ave, Boulder, CO 80304. Its main telephone number is 212-379-1097. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
This office is located at 8610 Seawall Blvd #D, Galveston, TX 77554. Its main telephone number is 512-609-1725. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
This office is located at 50 Congress St, Boston, MA 02109. Its main telephone number is 617-901-2517. Employees travel to that office by means of mass transit and automobile. We engage in investment banking here.
This office is located at 4201 Congress St, Ste 450, Charlotte, NC 28209. Its main telephone number is 704-551-3700. Employees travel to that office by means of mass transit and automobile. We engage in institutional equity trading here.
This office is located at 7777 Glen America Dr, Ste 353, Dallas, Tx 75225. Its main telephone number is 214-373-3600. Employees travel to that office by means of mass transit and automobile. We engage in institutional equity sales here.
This office is located at 330 Cumberland Blvd, Ste 353, Dallas, Tx 75225. Its main telephone number is 404-358-2109. Employees travel to that office by means of mass transit and automobile. We engage in institutional equity sales here.
Sunny Isle, FL
This office is located at 18501 Collins Ave #2803, Sunny Isle Beach, FL 33160. Its main telephone number is 512-609-1720. This is a private residence. We engage in order taking and entry, supervision and sales at this location.
Our Firm has the following unregistered locations:
This office is located at 5541 Ashton Lake Dr, Sarasota, FL 34231. Its main telephone number is 941-924-4633. This is a private residence. We engage in institutional sales here.
This office is located at 33B Putman Green, Greenwich, CT 06830. Its main telephone number is 203-249-7454. This is a private residence. We engage in institutional sales here.
This office is located at 27 Keiths Lane, Alexandria, VA 22314. Its main telephone number is 571-733-3100. This is a private residence. We engage in institutional sales here.
This office is located at 365 Calihan Rd, Booneville, AR 72927. Its main telephone number is 479-675-2788. This is a private residence. We engage in retail sales here.
This office is located at 1931 Crescent Park Dr., Reston, VA 20190. Its main telephone number is 212-379-1079. This is a private residence. We engage in institutional sales here.
This office is located at 636 Woodlake Dr, McQueeny, TX 78123. Its main telephone number is 713-706-6136. This is a private residence. We engage in institutional and retail sales here.
La Grange, IL
This office is located at 726 S Edgewood Lane, La Grange, IL 60525. Its main telephone number is 312-466-5559. This is a private residence. We engage in institutional and retail sales here.
V. Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff from the affected offices to the closest of our unaffected office locations. If none of our other office locations is available to receive the staff, we will move them to other locations based on availability. The firm is at an advantage in that its employees can essentially work from their homes should the situation warrant such a move.
VI. Customers’ Access to Funds and Securities
Our firm does not maintain custody of customers’ funds or securities. Hilltop Securities maintains all customer funds and securities pursuant to our clearing agreement. In the event of an internal or external SBD, if telephone service is available, our registered persons will take orders or instructions regarding customer accounts and contact Hilltop Securities. If Web access is available, our firm will also post on its website that customers may access their funds and securities by contacting Hilltop Securities at 214-953-4000. The firm will make this information available to customers through its disclosure policy.
If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation.
VII. Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records and its electronic records at various locations depending on the type of document. Each branch manager is responsible for the maintenance of certain books and records as outlined in the Firm’s Compliance Manual. Our firm maintains the following document types and forms that are not transmitted to our clearing firm: correspondence, blotter, logs and various documents used to evidence supervision.
Our firm maintains its back-up electronic copy of books and records through undisclosed off-site third-party vendors. These records are maintained on severs stored offsite. Mark Salter is responsible for the maintenance of these back-up books and records. Our firm backs up its paper records by copying and taking them to our back-up site. We back up our records, depending on document type, on a daily, weekly, or monthly basis.
The firm backs up its electronic records daily and weekly by an automated back-up process on our internal server. The information is also backed up to an external server.
In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our back-up site. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.
VIII. Financial and Operational Assessments
In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter-parties and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our web site, telephone voicemail, secure e-mail, etc. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).
Financial and Credit Risk
In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our clearing firm, critical banks and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including FINRA District Office in Dallas.
IX. Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. These systems include Bloomberg (order entry purposes); telephone systems (communications) and our computers (communications, account access and order entry).
We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking, entry, and execution. Our clearing firms provide, through contract, comparison, allocation, clearance and settlement of securities transactions, maintenance of customer accounts, access to customer accounts and the delivery of funds and securities.
Our clearing firms maintain business continuity plans and the capacity to execute those plans. Our clearing firms have represented that they will advise us of any material changes to its plan that might affect our ability to maintain our business. In the event one of our clearing firms executes its plan, it will notify us of such execution and provide us equal access to services as its other customers. If we reasonably determine that our clearing firm has not or cannot put its plan in place quickly enough to meet our needs or is otherwise unable to provide access to such services, our clearing firms will assist us in seeking services from an alternative source.
Our clearing firms have represented that they back up our records at a remote site. Our clearing firms represent that they operate back-up facilities in geographically separate areas with the capability to conduct the same volume of business as their primary sites. Our clearing firms have also confirmed the effectiveness of their back-up arrangements to recover from a wide scale disruption by testing on an ongoing basis.
Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption and status of critical infrastructure—particularly telecommunications—can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Our clearing firms have the following SBD recovery times and resumption objectives: recovery time period of within hours and resumption time of within the same day.
Compliance will maintain a copy of the clearing firms BCP disclosures as evidence of periodically reviewing our clearing firm’s capabilities to perform the mission critical functions the clearing firms have contracted to perform for our firm.
Our Firm’s Mission Critical Systems
Currently, our firm receives orders from customers primarily via telephone. During an SBD, either internal or external, we will continue to take orders through this and any other methods that are available and reliable. In addition, as conditions permit, we will inform our customers when alternate ways to communicate orders become available. Customers will be informed of alternatives by posting instruction on the website. If necessary, we will advise our customers to place orders directly with our clearing firms.
Currently, our Firm enters orders electronically into our order management systems—Bloomberg TOMS, FlexTrade, and Knight Direct—which automatically send the orders to our clearing firms. In the event of an internal SBD, we will enter and send records to our clearing firms by the fastest alternative means available, which may include telephone, email, or fax. In the event of an external SBD, we will maintain orders in electronic or paper format, and deliver the orders to the clearing firms by the fastest means available when they resume operations.
We currently execute orders by sending them to our clearing firms. In the event of an internal SBD, we would search for the best available channel to send orders to our clearing firms. In the event of an external SBD, we would do the same. If we are unable to send customer orders to our clearing firms, we may refer our customers to deal directly with the clearing firms.
Other Services Currently Provided to Customers
Order execution is the only service we provide customers. We do not hold any customer funds or securities.
Mission Critical Systems Provided by Our Clearing Firm
Our firm relies, by contract, on our clearing firms to provide order execution, order comparison, order allocation and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.
X. Alternate Communications Between the Firm and Customers, Employees, and Regulators
We now communicate with our customers using e-mail, Bloomberg, telephone, fax, U.S. mail, and in person visits at our firm or at the other’s location. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will contact them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.
We now communicate with our employees using telephone, fax, e-mail, US Mail, express delivery and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers (see Attachment A).
We are currently members of the FINRA, MSRB and SIPC. We communicate with our regulators using the telephone, e-mail, fax, U.S. mail and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.
XI. Critical Business Constituents, Banks, and Counter-Parties
We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them
in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm. The Firm currently has no major suppliers at this time.
We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD. The bank maintaining our operating account is:
Plains Capital Bank
325 N. Saint Paul St., Ste 800
Dallas, Tx 75201
Direct Phone: (866) 762-8392
Our Proprietary Account of Introducing Brokers/Dealers (PAIB account) is maintained at Hilltop Securities.
We have contacted our critical counter-parties, such as other broker-dealers or institutional customers, to determine if we will be able to carry out our transactions with them in light of the internal or external SBD. Where the transactions cannot be completed, we will work with our clearing firm or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible.
XII. Regulatory Reporting
Our firm is subject to regulation by FINRA, MSRB and the SEC. We now file reports with our regulators using paper copies in the U.S. mail, and electronically using fax, e-mail, and the Internet. In the event of an SBD, we will check with the SEC, FINRA, MSRB and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.
FINRA – District 6
12801 North Central Expressway
Dallas, TX 75243-1778
Fax: (972) 716-7646
1300 I Street NW, Ste 1000
Washington, DC 1000
Securities and Exchange Commission
Fort Worth Regional Office
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Fort Worth, TX 76102
XIII. Disclosure of Business Continuity Plan
Attached is the written BCP disclosure statement that our clearing firm provides to customers at account opening and annually (See Attachment B). We also post the disclosure statement on our website and mail it to customers upon request.
XIV. Updates and Annual Review
Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our firm will review this BCP annually as part of the CEO certification process required by supervisory controls rules and regulations, to modify it for any changes in our operations, structure, business or location or those of our clearing firm.
XV. Senior Manager Approval
I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.
Below you will find important information regarding the account opening process at NatAlliance Securities, LLC.
In an effort to assist the government in their fight against money laundering and terrorism within the United States, federal law mandates that all financial institutions obtain, verify and record specific information that identifies each person and/or entity that opens an account.
When opening an account at NatAlliance Securities we are required by law to collect the following information from you:
- Your name
- Date of birth
- Social security number or employer identification number, or; if you are a non-U.S. citizen we will require a taxpayer identification number, passport number, country of issuance, alien identification card number or government-issued identification showing nationality, residence and a photograph of you.
- We also require a copy of your driver’s license or passport or any legal document with a photograph of you that has been issued by a state or federal authority.
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.
The U.S. Department of Treasury, Securities and Exchange Commission, FINRA and New York Stock Exchange rules require you to provide this information. These rules may also require you to provide additional information such as your net worth, annual income, occupation, employment information, investment experience and objectives as well as your risk tolerances.
If you refuse to provide the aforementioned information or if your identity can not be verified, we will not open an account and/or conduct transactions on your behalf. Please understand that NatAlliance Securities will take the necessary precautions to assist the financial industry and U.S. government in their fight against terrorism and money laundering to maintain a fair and equitable market place.
NatAlliance maintains a clearing arrangement with Hilltop Securities, Inc. for clearing fixed income, institutional equity business, and retail equity trades.
Disclosure of SEC-Required Order Execution Information:
Pursuant to SEC Rule 606, NatAlliance Securities, LLC (NAS) is required to make publicly available a quarterly report with regard to its routing of non-directed orders. These reports also include information about NAS’ relationship with certain market centers to which it routes orders. NAS’ Rule 606 reports can be found at: Rule 606A1 – Held Compliance report. Detailed information about routing and execution of customer’s orders, including the market centers to which customer’s orders were routed, whether such orders were directed or non-directed orders, and the time of the transactions, if any, that resulted from such orders, is available at no cost upon request via telephone to (512) 609-1700.
NAS by default routes held, retail orders to its clearing firm, Hilltop Securities, Inc. Hilltop Securities makes the routing decisions for those orders. HTS is required to make publicly available a quarterly report with regard to its routing of non-directed orders. This information can be accessed on the internet at: https://www.hilltopsecurities.com/disclosures/order-routing-disclosure/ or a written copy will be furnished at no cost upon request via telephone to (214) 859-1800.
Pursuant to SEC Rule 607, NatAlliance Securities LLC (NAS) is required to disclose its payment for Order Flow practices. NAS sends certain equity orders to exchanges, electronic communication networks, or broker / dealers during normal business hours and during extended trading sessions. Those market centers do not provide payments to NAS for order flow. NAS does receive rebates and/or receives charges based on providing or taking liquidity, which is a passthrough from various exchanges. In addition, NAS will not and does not execute equity orders as principal. NAS does not receive payments for directing listed options order flow to certain option exchanges. This disclosure only applies to orders directed to NAS by your firm.