Disclosures
Policies, Forms, and Documents
Privacy Policy
KCD Financial, Inc. (KCD) is committed to protecting your privacy and the confidentiality of your personal and financial information. The measures we take to keep your personal information private and secure are outlined below.
How We Protect Confidentiality
KCD uses procedural, physical, and electronic system safeguards to store and secure information about you in compliance with federal standards. Our systems protect your information from unauthorized access, alteration, and destruction. Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities. When we enter into agreements with other companies to provide services available to you, we include a confidentiality clause. Under such an agreement, these companies may receive information about you, but they may only use it for the intended purpose – to benefit you.
Persons Covered Under Policy
The KCD Privacy Policy applies to anyone who is a current or former KCD brokerage client, including those customer accounts of our correspondent broker-dealers, or who registers with one of our services or promotional offers. We provide you with a copy of this policy when you open an account, and annual notifications can be accessed through our website (www.kcdfinancial.com) thereafter. If we change our policy regarding the sharing of information, we will notify you in advance and give you the opportunity to “opt-out” of such disclosure.
Method for Obtaining Information
In the normal course of business, we collect, retain, and use information about you to serve your financial needs, administer your account(s), and inform you of products and services that may be of interest. This data, known as non-public personal information, may be collected from several sources, including: applications and other forms you file with us (e.g., name, assets, income), records of transactions with us, our affiliates, non-affiliated third parties and others (e.g., credit report). Because we strive to provide you with the best possible service, the accuracy, and completeness of your personal information is important to us. We ask that you review your information regularly to ensure that it is correct. Please contact your account representative or KCD directly if you need to correct or update your personal information.
Information Sharing
KCD does not sell your personal information to anyone. We restrict the types of information we share and the types of entities with whom we share it. The primary reason for sharing information about you is to increase your convenience in transacting business with us and to give you more financial service choices.
We do not disclose personal information to non-affiliated third parties unless one of the following exceptions applies:
We disclose personal information to service providers that assist us in processing your transactions or servicing your account(s). An example would be the company that prints and mails your account statement.
We disclose or report personal information in limited circumstances when we believe in good faith that disclosure is required or permitted under law. For example, we would provide information in cooperation with securities regulators or law enforcement authorities, to resolve consumer disputes, or to perform credit evaluations and authenticated checks.
Opt-Out Option and Change Notices
If for any reason at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to “opt-out” of such disclosure.
Business Continuity Plan
KCD Financial, Inc. (KCD) 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 is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our Business Continuity Plan.
Contacting Us
If after a significant business disruption you cannot contact us as you usually do at (920) 347-3400, you should call our alternate office location at (262) 436-8715 or go to our web site at www.kcdfinancial.com. If you cannot access us through either of those means, you should contact our clearing firm, Hilltop Securities, at (214) 953-4000 or www.hilltopsecurities.com for instructions on how it may provide assistance to accomplish your requests; such as: account information, trade requests or availability of funds. Additionally, if you’re a customer with assets held directly at an investment company and not through Hilltop Securities, you may contact them directly at the investor telephone number provided on your account statement(s).
Our Business Continuity Plan
We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our Business Continuity Plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our Business Continuity Plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Hilltop Securities, backs up our important records in a geographically separate area, as do any direct investment companies we do business with. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within the next business day or sooner. Your orders and requests for funds and securities could be delayed during this period. This holds true for direct investment companies you may do business through.
Varying Disruptions
Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within the next business day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within the next business day. In either situation, we plan to continue in business, transfer brokerage operations to our clearing firm if necessary, and notify you through our web site www.kcdfinancial.com on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
To obtain more information about our Business Continuity Planning, you may contact us at:
KCD Financial, Inc.
3061 Allied St, Suite B, Green Bay, WI 54304
(920) 347-3400
Fax: (920) 347-3402
Customer ID Program
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 opens an account.
When an account is opened, the client will be asked for their name, address, date of birth, and other information that will allow us to identify them. We may also ask to see a driver’s license 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, partnership, or trust agreement.
US Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.
If your identity cannot be established, our Firm may not be able to open an account or carry out transactions for you.
SEC Order Execution & Routing
U.S. Securities and Exchange Commission (“SEC”) Rule 11Ac1-6 requires all brokerage firms to publicly disclose their order routing practices. Disclosure is to describe routing of “non-directed orders,” that is, orders that customers have not specifically asked to have sent to a particular venue for execution. For these non-directed orders, we select the venue on behalf of our customers. With respect to KCD Financial, Inc., relationships with trading venues, KCD Financial, Inc., directs all trades in over-the-counter (OTC), listed stock, and options to our clearing firm, Hilltop Securities, for execution.
KCD Financial, Inc. does not receive compensation for directing this order flow to Hilltop Securities. The designated market makers to whom orders are automatically routed are selected based on the consistently high quality of their executions in one or more market segments and their history of seeking price improvements. Hilltop Securities regularly reviews reports for quality of execution purposes.
Links Disclosure
Links provided from this web site are strictly for informational purposes and are not an endorsement or recommendation of the site, company, content, or its sponsoring organization by KCD Financial, Inc. KCD provides these links as a convenience to registered representatives of the firm and has not tested any software or verified any information found at such sites. Risks are associated with the use of software and the information available on the Internet and you acknowledge and understand these risks before using any of these services.
Broker/Dealer Disclosure
The information on this site is not intended to be used as the primary basis for investment decisions.
Products and services described may not be eligible for solicitation in your state. This site is for use by individuals residing in states where our products and services may legally be offered.
This site has been published in the United States for residents of the United States. We do reserve the right to require proof of residence from any user accessing this site and requesting information. It is not intended for use by, or to provide any information to investors outside of the United States. Investors outside of the United States are subject to securities and tax regulations within their applicable jurisdictions that are not addressed on this site.
Potential Conflicts of Interest
KCD Financial, Inc., offers a wide range of mutual fund, variable annuity, variable life insurance, Direct Participation Programs (“DPPs”), Real Estate Investment Trusts (“REITS”), equities, fixed income and third party money management services through both our clearing firm, Hilltop Securities, and through direct selling agreements with the sponsoring companies. The purpose of the disclosure document is to provide information regarding the costs associated with investing in these products, how the representative is compensated when clients purchase these products and how KCD Financial, Inc. is compensated by the sponsor companies.
KCD Financial, Inc. holds the fundamental belief that each investor with the guidance of their representatives has the right to choose the investments that provide the greatest chance of achieving their financial goals. As such, we do not offer proprietary products and do not maintain a list of preferred investment companies. We do, however, have the responsibility to disclose fees and potential conflicts of interest in order for the client to make an informed decision before investing in certain products. Therefore, a description of customary sales charges, compensation, and additional support associated with these investments is available upon request. Your request may be directed to:
KCD Financial, Inc.
Attn: Chief Compliance Officer
3061 Allied St, Suite B
Green Bay, WI 54304
920-347-3400
Member FINRA/SIPC
Order Routing Disclosure
To obtain best execution and redundant execution facilities, KCD relies on our clearing agent, Hilltop Securities, who routes equity and option orders to a diverse group of market centers and regularly monitors the quality of the executions received.
To see the Hilltop Securities disclosure, please go to this link: Order Routing Disclosure – Hilltop Securities
