SEC Rule 606 & 607:

(Disclosure of Payment for Order Flow and Order Routing Information)

All VBC Securities’ orders for listed, NASDAQ and OTC securities are directed to Hilltop Securities Inc. (HTS) for order execution. 

 

Pursuant to SEC Rule 606, 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: www.hilltopsecurities.com, or a written copy will be furnished at no cost upon request via telephone to (214) 859-1800. 

SEC Rule 606(b) requires a broker-dealer to disclose to its customers, upon request, “the identity of the venue to which the customer’s orders were routed for execution in the six months prior to the request, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, that resulted from such orders.”

 

Pursuant to SEC Rule 607, HTS is required to disclose its payment for Order Flow practices. HTS sends certain equity orders to exchanges, electronic communication networks, or broker-dealers during normal business hours and during extended trading sessions.  Some of those market centers provide payment to HTS, or charge access fees depending upon the characteristics of the order and any subsequent execution.  In addition, HTS may execute certain equity orders as principal.  The details of these payments and fees are available upon request. HTS receives payments for directing listed options order flow to certain option exchanges.  Compensation is generally in the form of a per-option contract cash payment.  This disclosure only applies to orders directed to HTS by VBC.

 

NYSE Rule 382 Notice Regarding Introducing Broker:

The Notice Regarding Introducing Broker sets forth, in detail, the division of responsibilities and the duties of HTS and VBC.  However, it is not meant as a complete listing of every possible circumstance, but only as a general disclosure.   The VBC client has a direct relationship with their chosen registered representative and nothing in the clearing and operational services provided by HTS to VBC alters that relationship.  View the notice by clicking below.

Introducing Broker Notice

FINRA Regulation for Margin Account:

The Margin Disclosure Statement is furnished to clients in order to provide some basic facts regarding securities purchased on margin.  Make sure to read the margin agreement carefully before trading stocks in a margin account.  View the statement by clicking below.

Margin Disclosure Statement

Characteristics & Risks of Standardized Options:

The Options Clearing Corporation (OCC) booklet, Characteristics & Risk of Standardized Options, and any updates or amendments can be viewed by clicking below.

OCC Booklet

VBC Jurisdiction Registration:

VBC is currently licensed to sell securities in the following states as a broker-dealer: Arizona, Colorado, Connecticut, Florida, Georgia, Maine, Maryland, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Virginia and Texas

 

VBC currently has life insurance brokers licensed in: New Jersey and New York

VBC Privacy Policy:

VBC takes your personal privacy seriously. Because we value client relationships, we do not sell client information or share it with outside organizations.  View Notice of Privacy Policy and Web Privacy Policy by clicking below.

VBC Privacy Policy

VBC Business Continuity Plan:

VBC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business.  Since the timing and impact of disasters and disruptions are unpredictable, we have to be flexible in responding to actual events as they occur.  View the written continuity plan by clicking below.

VBC Continuity Plan

VBC Data Security Policy Statement:

VBC has created this Data Security Policy Statement as a resource that it may use with the intent to establish a prudent process as it relates to data security and our customers. View the Data Security Policy  Statement by clicking below.

VBC Data Security Policy Statement

VBC Fee Schedule for Commission Based Accounts:

When you purchase or sell a security, you pay a commission or fee.  The amount you pay depends on the amount of principal involved. View the Fee Schedule of Commission Based Accounts by clicking below.

VBC Fee Schedule for Commission Based Accounts

HTS Correspondent Customer Information Brochure:

HTS charges you a number of fees connected to your account(s). These fees compensate

HTS for maintaining your accounts, performing certain transactions involving your account(s),

reporting requests, and other services. These fees are deducted from your account(s).  This information can be accessed on the internet at: https://www.hilltopsecurities.com/media/1289/Correspondent-Customer-Information-Brochure.pdf

VBC Securities, LLC Brokerage Services Disclosure Brochure:

The purpose of this brochure is to further explain the scope and terms of the relationship among VBC, VBC’s financial professional, and you as a retail customer of VBC.  In this brochure, we explain the following: (i) VBC and your financial professional act as a broker-dealer and an associated person of a broker-dealer; (ii) the type and scope of services provided to you, including certain limitations on the securities or investment strategies involving securities that may be recommended to you; (iii) the fees and costs that apply to your transactions, holdings, and accounts; and, (iv) the conflicts of interest that are associated with the

recommendations we make.

Brokerage Services Disclosure Brochure

VBC DOL Fiduciary Affirmation Disclosure:

When we at VBC provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours.

Under this special rule’s provisions, we must:

  • Meet a professional standard of care when making investment recommendations (give prudent advice);

  • Never put our financial interests ahead of yours when making recommendations (give loyal advice);

  • Avoid misleading statements about conflicts of interest, fees, and investments;

  • Follow policies and procedures designed to ensure that we give advice that is in your best interest;

  • Charge no more than is reasonable for our services; and

  • Give you basic information about conflicts of interest.

VBC MSRB Rule G-10 Annual Notifications to Customers:

On an annual basis VBC Securities will provide the following written or electronic notice to customers who have effected transactions in municipal securities within the prior one-year period or who hold a municipal securities position:

  • VBC Securities is registered with the SEC and the MSRB;

  • the MSRB's website address (www.msrb.org); and

  • a statement about the availability of a brochure available on the MSRB's website describing protections provided by MSRB rules and how to file a complaint with the appropriate regulatory authority.

 

Notification must be provided every 12 months starting at any time during the calendar year and within the following rolling 12-month period.

The following notice appears annually on all 1st Quarter Customer Statements:

VBC Securities is registered with the SEC and the MSRB.  The MSRB website is www.msrb.org.  An investor brochure is available on the MSRB website and describes the protections that may be provided by the MSRB rules and how to file a complaint with an appropriate regulatory authority.

VBC Registered Representative Login: For representative use only.

Registered Rep Login

 

Other helpful websites:

FINRA - Financial Industry Regulatory Authority - www.finra.org

SIPC - Securities Investor Protection Corporation - www.sipc.org

SEC - U.S. - Securities and Exchange Commission - www.sec.gov

MSRB - Municipal Securities Rulemaking Board - www.msrb.org