CIP & Reg S-P Notices

Important Information You Need to Know About Our Account Requirements and Confidentiality Pledge

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record account information. At William O’Neil + Co. Incorporated (“the Firm”), we collect public and nonpublic information about our institutional clients as specifically mandated for customer identification and verification by the US PATRIOT ACT, SEC 17a-3 (Books & Records Requirements).

This Notice provides you with some answers about the Firm’s Customer Identification Program (“CIP”).

What types of information will I need to provide?

To open an institutional account, the Firm is required to obtain from you information such as the following:

A corporation, partnership, trust or other legal entity needs to provide information about its principal place of business, local office, certified articles of incorporation, government-issued business license, LLC agreement, partnership or trust agreement, as applicable to the organization of the firm. To comply with the regulations, the Firm is required to record and verify the information that is noted in these documents, such as:

  1. who at your organization is authorized to conduct business on it’s behalf, and
  2. if you intend to trade with our equity desk, we will also need you to provide us with a trading authorization signed by one of the parties authorized to conduct business at the organization level.

The Firm has developed a fill-in-the blank form for your convenience to satisfy both 1 & 2 above.

What happens if I don’t provide the information requested or my identity can’t be verified?

The Firm will be unable to open an account or carry out transactions for your organization. If you have not furnished the Firm with the above information and your firm had an existing account already opened, the Firm may have to close it. If you have not already done so, please contact your Account Manager to provide any of the necessary information noted above.

What is William O’Neil + Company’s Privacy Policy?

Equally important to our firm and to our clients is our Privacy Policy.

This CIP information is maintained in strict confidence. William O’Neil + Company does not disclose client information to anyone, unless such disclosure is required by law.

We restrict access to account information to only those employees who are required to have the information in order to provide services to you. We maintain physical, electronic, and procedural safeguards to secure your information. If an institutional client closes an account with William O’Neil + Company, we will continue to adhere to this confidentiality pledge.

We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.