VBC Securities, LLC

Hilltop Securities Inc.

 

Disclosure required by NASD Rule 3230 and NYSE Rule 383

 

 Carrying Agreements - FINRA Rule 4311

 

The firm with which you have opened your securities account has retained Hilltop Securities Inc. (HTS) to provide certain record keeping or operational services. These services such as the execution and settlement of securities transactions, custody of securities and cash balances, and extension of credit on margin transactions are provided under a fully disclosed Clearing Agreement between HTS and your firm. As a member of FINRA, HTS is required (under NASD Rule 3230 and NYSE Rule 382) to disclose to you the details of our fully disclosed Clearing Agreement with your firm, which are summarized below.

 

Responsibilities of Your Firm 

Your financial organization has the responsibility to:

 

· Approve the opening of your account

 

· Obtain necessary documentation to help fight the funding of terrorism and money laundering activities

 

· Service and supervise your account through its own personnel in accordance with its own policies, procedures, applicable laws, and regulators

 

· Know you and your stated investment objectives

 

· Provide appropriate investment advice, recommendations, or management services based on your investment objectives

 

· Determine whether particular kinds of transactions such as margin, option, and short sale are appropriate for you

 

· Obtain the initial margin as required by Regulation T if a margin account is opened for you

 

· Accept and, in certain instances, execute securities orders

 

· Know the facts about any orders for the purpose or sales of securities in your account

 

· Comply with fair pricing and disclosure responsibilities (if your firm is a market maker in any securities or otherwise trades as principal with you)

 

· Correctly identify and promptly forward funds or securities intended for your account to HTS

 

· Supervise the activities of any individual who services your account

 

· Resolve any complaints regarding the handling of your account

 

· Manage the ongoing relationship that it has with you

 

Hilltop Securities Inc. has no involvement and assumes no responsibility in all of the above matters relating to the servicing of your account.

 

Responsibilities of Hilltop Securities Inc.

In general HTS is only responsible for the services within the scope of the Clearing Agreement that are provided at the request of your firm and contains specific direction regarding your account. As such, HTS may fulfill the following responsibilities on behalf of your account:

 

· Create computer-based account records

 

Rev.10/15