Additional Disclosures

ClearList LLC and ClearList Securities LLC (collectively, “ClearList”) are U.S. registered Securities and Exchange Commission (“SEC”) broker-dealers, members of the Financial Industry Regulatory Authority (“FINRA”). To meet regulatory requirements, ClearList is providing the below disclosures for your information. Should you have any questions regarding this letter, please contact compliance@clearlist.com. No action is required of you regarding the production of this disclosure notice.

FINRA Rule 2261

DISCLOSURE OF FINANCIAL INFORMATION TO CUSTOMERS

Pursuant to “FINRA Rule 2261: Disclosure of Financial Condition to Customers” issued by the Financial Industry Regulatory Authority (“FINRA”), ClearList will make available to customers on request information contained in our most recent balance sheet. If interested, please contact:

Securities Exchange Act Rule 17a-3(a)(18)

CUSTOMER COMPLIANT DISCLOSURE

In the event a customer would like to register a complaint regarding ClearList, please contact us at the following address:

FINRA Rule 2267

INVESTOR EDUCATION AND PROTECTION

Pursuant to “FINRA Rule 2267: Investor Education and Protection”, ClearList would like to remind customers that they may obtain information regarding FINRA BrokerCheck and FINRA itself at the following contact details:

FINRA Website: https://www.finra.org/#/

FINRA BrokerCheck: https://brokercheck.finra.org/

FINRA BrokerCheck online informational website: https://www.finra.org/investors/learn-to-invest/choosing-investment-%20professional/about-brokercheck

For further questions regarding FINRA BrokerCheck, please do not hesitate to call the BrokerCheck telephone hotline number at 800–289-9999.

Securities Exchange Act Rule 17a-3(a)(18)

CUSTOMER COMPLIANT DISCLOSURE

Pursuant to “FINRA Rule 2266: SIPC Information to Customers”, ClearList would like to remind customers that they may obtain information about the Securities Investor Protection Corporation (“SIPC”), including the SIPC brochure, by contacting SIPC at the following contact information:

SIPC Website: https://www.sipc.org/  

SIPC Brochures: https://www.sipc.org/news-and-media/brochures

USA PATRIOT ACT ANTI-MONEY LAUNDERING NOTICE

Under the U.S. Patriot Act, we are required to establish and maintain an anti-money laundering program containing policies and procedures to know our customers. To help the government fight the funding of terrorism and money laundering activities, Federal law requires financial institutions to obtain, verify, and record information that identifies each person who establishes a relationship with the Firm. What this means for you: When you establish a relationship with the Firm, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

FINRA Rule 4370

Business Continuity Plan Disclosure “BCP”

ClearList LLC and ClearList Securities LLC (collectively, “ClearList”) are committed to safeguarding the interests of our subscribers in the event of an emergency or significant business disruption. This Business Continuity Plan (the “BCP”) Disclosure summarizes ClearList’s efforts to mitigate risks inherent with unforeseen business interruptions. ClearList’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our subscribers even in the event of an emergency or significant business disruption (“SBD”).  This BCP is intended to comply with the rules promulgated by the Financial Industry Regulatory Authority (“FINRA”).

ClearList’s policy is to respond to significant business disruptions by safeguarding Associated Persons’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of ClearList’s books and records, and ensuring that our clients can continue to transact business. Examples of potential scenarios that might cause some changes to our regular business operations:

  • In the event an SBD of any type which affects our primary office in New York, we will transfer our business operations to one or more remote sites in the United States.
  • We do not anticipate that power outages at our primary office will require us to shut down our business.

No contingency plan can eliminate all risk of service interruption or temporarily impaired access to ClearList. We will evaluate and revise our BCP to address risks to the extent possible. In developing our BCP, we have made certain assumptions regarding accessibility and availability of alternative facilities, the ability of a sufficient number of our personnel to man our systems, and external organizations including securities markets and government agencies being operational. If these assumptions are not valid under particular circumstances, we will evaluate possibilities for minimizing the disruption to services as feasible at that time.

We will update the BCP as needed in the event of changes to our business processes, technology and staff. We will continue to post updated information on our website. Users may also obtain our current BCP summary by submitting a written request to:

Email: compliance@clearlist.com

Subject Line: Business Continuity Plan

Disclaimer

ClearList’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients even in the event of an emergency or significant business disruption; however it is not without limits. The BCP is designed to work in many different emergency situations, but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption.

Although we are confident in our own preparedness, ClearList has no control over the various entities that we must rely upon in the event of an emergency. Our BCP is tested periodically to ensure readiness. However, such tests may not be able to replicate the actual conditions we experience in a real emergency.

This BCP disclosure statement is subject to change without notice. In the event that the BCP or the BCP disclosure statement is modified, the updated document will be promptly posted on the ClearList internet website. Alternatively, clients of ClearList may obtain an updated hard copy of the BCP disclosure statement upon request. The information contained in this BCP disclosure statement is provided by ClearList for informational purposes only. Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any client agreement between you and ClearList.