LEGAL & COMPLIANCE
BUSINESS CONTINUITY PLAN
As required by securities industry regulations, Tudor, Pickering, Holt & Co. (“TPH” or our “Firm”) wants to make you aware that we have developed a Business Continuity Plan on how we will respond to events that may disrupt our business. Since the timing and impact of disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.
Our Business Continuity Plan
Significant business disruptions can vary from disrupting only our Firm to the region in which we are located. Our Business Continuity Plan (our “Plan”) addresses various disruptions and is intended to mitigate reasonable risk so as to permit the continuation of key business operations. Our Plan addresses data back-up and recovery, mission critical systems, safeguarding our employees and property, financial and operational assessment, alternative communications with customers, employees and regulators, alternate physical location of employees, critical supplier and bank, and counterparty impact, regulatory reporting and assuring our customers prompt access to their funds and securities and allowing our customers to transact business.
TPH maintains redundant offsite archival storage facilities in a geographically separate area. Our clearing firm, the Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated, also backs up certain of our sales and trading records for our Tudor, Pickering, Holt & Co. Securities, LLC subsidiary. We have designated an alternate site to conduct key business operations until we are able to return to our offices. Our Firm’s goal is to recover its critical operations within minutes or hours after the disruption. In the event of a disaster, Tudor, Pickering, Holt & Co. Securities, LLC will provide its customers prompt access to their funds and securities held at its clearing firm.
In the event of a business disruption, TPH will provide important information to its employees and clients via call forwarding, e-mail and postings to our Firm’s webpage located at www.tphco.com. Our address is:
1111 Bagby, Suite 5100
Houston, TX 77002
If you are a sales and trading client of Tudor, Pickering, Holt & Co. Securities, LLC and you are unable to reach us during a business disruption, you may contact our clearing firm, the Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated, for trade related information. Their contact information is as follows:
Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated
101 Hudson Street
Jersey City, NJ 07302
The plan is subject to modification, an updated summary will be promptly posted on our website, www.tphco.com. Customers may alternatively obtain updated summaries by requesting a written copy by mail. Please direct any such inquiries to the Compliance Department.
TPH’s North American regulated companies covered by our Plan: Tudor, Pickering, Holt & Co. Securities, LLC*.
*Clearing firm services are only applicable to the business services of Tudor, Pickering, Holt & Co. Securities, LLC
In the event you should have a question or complaint that you would like to register with our Firm, please contact the Compliance Department at:
Tudor, Pickering, Holt & Co. Securities, LLC
Attn: Compliance Department
1111 Bagby, Suite 4900
Houston, TX 77002 USA
Tudor, Pickering, Holt & Co. Securities – Canada, ULC
Attn: Compliance Department
Suite 2110, 250 – 6th Avenue SW
Calgary, AB T2P 3H7
© Tudor, Pickering, Holt & Co. 2022. No person may reproduce any portion of the content on this website without prior written consent of Tudor, Pickering, Holt & Co. “Content” refers to any materials, documents, images, graphics, logos, design, audio, video and any other information provided from or on our site.
Email is confidential and is intended only for the individual named. The information contained in an email may not be disclosed, copied or disseminated, in whole or in part, without the prior written permission of Tudor, Pickering, Holt & Co. (“TPH”). Email communications are based on information which Tudor, Pickering, Holt & Co. believes is reliable. However, TPH does not represent or warrant its accuracy. Email messages should not be considered as an offer or solicitation to buy or sell any securities. Securities offered through Tudor, Pickering, Holt & Co. Securities, LLC, Member FINRA/SIPC and Tudor, Pickering, Holt & Co. Securities – Canada, ULC, Member IIROC/CIPF.
Under FINRA Rule 2210, TPH email communications are deemed institutional sales material and are not meant for distribution to retail investors. Recipients should not forward TPH email communications to a retail investor.
INFORMATION SHARING FOR MARKETING PURPOSES
Federal law gives you the right to limit information sharing between affiliated entities for marketing purposes. It also requires us to give you this notice to tell you about your choices to limit information sharing for marketing purposes.
This notice is being provided on behalf of Tudor, Pickering, Holt & Co. Securities, LLC. You may limit our affiliates from marketing products or services to you based on your personal information that they collect and share with one another. This information includes your contact information, account history.
To prohibit information sharing for marketing purposes, please contact the Compliance Department at email@example.com or call collect at 713-333-7100. Your instruction to limit marketing offers from our affiliates will remain in effect until you tell us to make a change.
This website is for informational purposes only and does not constitute an offer to sell or solicitation of an offer to buy any security which may be referenced on this website. Offers can only be made where lawful under applicable law.
Tudor, Pickering, Holt & Co. (“TPH”) considers your privacy our utmost concern. In order to provide you with individualized service, we collect certain personal, non-public information about you from information you provide on applications or other forms and information about your account transactions with us. We may also collect such information through your account inquiries by mail, email, or telephone.
- Use of Your Data. We may use your information for any purpose in our discretion. In general, information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. TPH uses your information for research, marketing, and general purposes; identify you as a user in our system; provide improved administration of our services; improve the quality of experience when you interact with our research reports and services; send you administrative e-mail notifications; respond to your inquiries; send promotional communications; make telephone calls to you, from time to time, as a part of secondary fraud protection; and to solicit your feedback. We may create anonymous data records from information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our services and improve site navigation. TPH reserves the right to use and disclose anonymous data to third party companies for any purpose in its discretion. If you provide feedback on any of our services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your information.
We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. Specifically, so that we may continue to offer you products and services that best meet your investing needs, and to effect transactions that you request or authorize, we may disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf, such as transfer agents, or printers and mailers that assist us in the distribution of investor materials. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose.
If you decide at any point either to end your relationship with us or to become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.
With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
If you should have any questions or comments about our Customer Identification Program, please contact our Compliance Department on 713-333-7100 or 713-333-2960. You may write to us at the following address:
Tudor, Pickering, Holt & Co. Securities, LLC
Attn: Compliance Department
1111 Bagby, Suite 4900
Houston, Texas 77002
SOCIAL MEDIA DISCLOSURES
Tudor, Pickering, Holt & Co. and its affiliated companies (“TPH”) reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. is the trade name for Tudor, Pickering, Holt & Co. Securities, LLC, Member of FINRA & SIPC. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH will not accept purchase or sales orders via Twitter or any social media systems, and reminds all users not to disclose any personal financial information on Twitter. TPH is not responsible for third parties that may be linked to this page or to other Twitter pages, including but not limited to content posted by third parties, the privacy and security policies of Twitter or any other third-party sites, or for the products or services offered by any third party.
Tudor, Pickering, Holt & Co. and its affiliated companies (“TPH”) reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. is the trade name for Tudor, Pickering, Holt & Co. Securities, LLC , Member of FINRA & SIPC. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH will not accept purchase or sales orders via LinkedIn or any social media messaging systems, and reminds all users not to disclose any personal financial information on LinkedIn. TPH is not responsible for third parties that may be linked to this page or to other LinkedIn pages, including but not limited to content posted by third parties, the privacy and security policies of LinkedIn or any other third-party sites, or for the products or services offered by any third party. All statements and messages are for U.S. residents only.
Tudor, Pickering, Holt & Co. and its affiliated companies (“TPH”) reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. is the trade name for Tudor, Pickering, Holt & Co. Securities, LLC, Member of FINRA & SIPC. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH will not accept purchase or sales orders via Facebook or any electronic messaging systems, and reminds all users not to disclose any personal financial information on Facebook. TPH is not responsible for third parties that may be linked to this page or to other Facebook pages, including but not limited to content posted by third parties, the privacy and security policies of Facebook or any other third-party sites, or for the products or services offered by any third party. All statements and messages are for U.S. residents only.
For detailed rating information, distribution of ratings, price charts and disclosures regarding compensation policy and investment banking revenue, please visit https://tphco.bluematrix.com/sellside/Disclosures.action.
FINRA Rule 2267 requires that member firms provide clients with the FINRA BrokerCheck Hotline Number (800-289-9999), FINRA web site address (www.finra.org) and a notification that a brochure describing BrokerCheck is available from FINRA by contacting FINRA through their web site.
CUSTOMER IDENTIFICATION PROGRAM NOTICE
IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT
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 DOES THIS REQUIREMENT MEAN TO YOU?
When you open an account, we will ask for your name, address, date of birth and identification number. The identification for a U.S. citizen would be a taxpayer identification number or social security number. For a non-U.S. citizen, the identification number would include a (i) taxpayer identification number, (ii) a passport number along with country of issuance, (iii) alien identification number, or (iv) a government-issued identification document indicating nationality, residence, as well as your photo. We may also ask to see or copy your driver’s license, passport or other identifying documents.
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.
Absent specific order routing instructions from customers, TPHCS transmits orders to various market centers based on a number of factors. Such factors may include the following: the ability of a market center to execute the orders at or superior to the national best bid and offer (NBBO); the ability of a market center to provide price improvement opportunities; the speed of execution; the availability of efficient, automated transaction processing; liquidity enhancement opportunities; the speed of displaying better-priced limit orders; trading characteristics of the particular securities; and the extent to which different markets may be more suitable for different types of orders or different securities.
PAYMENT FOR ORDER-FLOW DISCLOSURE
Tudor, Pickering, Holt & Co. Securities, LLC does not engage in any formal arrangement for the payment for order flow from securities transactions. From time to time, when TPHCS routes orders to a particular market center and is in a position to provide liquidity, a market center may provide TPHCS with a rebate for that order flow.
SEC RULE 13H-1 – LARGE TRADER RULE
The Large Trader Rule requires large traders to register with the SEC and obtain a large trader ID. The Large Trader Rule defines a large trader as any person that:
- Directly or indirectly, including through other persons controlled by such person, exercises investment discretion over one or more accounts and effects transactions for the purchase or sale of any NMS security for or on behalf of such accounts, by or through one or more registered broker-dealers, in an aggregate amount equal to or greater than:
- During a calendar day, either two million shares or shares with a fair market value of $20 million; or
- During a calendar month, either twenty million shares or shares with a fair market value of $200 million; or
- Voluntarily registers as a large trader by filing electronically with the Commission on Form 13H. Please consult with your legal counsel to determine the applicability of the Larger Trader Rule to your activities.
SEC RULE 606 – REPORT DISCLOSURE OF ORDER ROUTING INFORMATION: CLICK HERE
Tudor, Pickering, Holt & Co. has prepared this report disclosure pursuant to U.S. Securities and Exchange Commission Rule 606 requiring all brokerage firms to publicly disclose, on a quarterly basis, reports on the top execution venues to which certain orders are routed for execution. The report provides information on the routing of “non-directed orders” – any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Tudor, Pickering, Holt & Co. has selected the execution venue on behalf of its customers. Currently, Tudor, Pickering, Holt & Co. generally does not accept orders on a “non-directed” basis.
Best Execution & Order Handling
As an IIROC Dealer Member, TPHC is required to establish, maintain and ensure compliance with written policies and procedures that are reasonably designed to achieve best execution when acting for a client. TPHC uses the facilities of three executing brokers when routing orders to the various marketplaces in Canada. Below are links to their best execution policies and procedures
Tudor, Pickering, Holt & Co. Securities, LLC is a member of the Securities Investor Protection Corporation (SIPC). Please be advised that you may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at www.sipc.org or 202-371-8300.