Terms of Use – Cohen & Company

Cohen & Company WEBSITE TERMS OF SERVICE

This content is for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security referred to. By accessing and using this site you agree to the following Terms of Service:

The material on this website is for informational purposes only, and is subject to change. The products and services described are only offered in jurisdictions in which they may be lawfully offered, and are subject to the terms of an agreement acceptable to both parties.
Certain phrases contained in this website may be either trademarks or service marks.
The information and materials contained in or provided through this site are provided “as is.” No warranty concerning the accuracy, adequacy, or completeness of such information and materials is made and we expressly disclaim liability for errors or omissions in such information and materials. No warranty of any kind, expressed or implied, including but not limited to, Warranties of Merchantability, Noninfringement, or Fitness for Any Particular Purpose, is given in conjunction with such information and materials.
In no event will Cohen & Company or its affiliates be liable for any damages, including without limitation, direct, indirect, punitive, special, consequential or other damages, losses or expenses (including attorney’s fees) arising in connection with this site or use thereof, or inability to use this site by any party.
Copyright in the pages and in the screens displaying the pages, and in the information and material therein and in their arrangement, is owned by Cohen & Company, unless otherwise indicated. Any use of the information and materials included in this site, including but not limited to, reproduction, public display, public performance, public distribution or any use for public or commercial purposes, without the written permission of Cohen & Company is prohibited.
Neither the information, nor any opinion expressed in this site constitutes an offer by Cohen & Company or any of its affiliates to buy and sell any securities or financial instruments or to provide any investment advice.
We may revise these terms without prior notice. If we change these terms materially, we will post a notice on this page or our home page to notify you of the change. Please read any such notice and the new terms. Your continued use of this site after we post such notice will constitute your acceptance of the new terms and their application to your use of this Web site as if they were the initial terms.

BEST EXECUTION / PAYMENT FOR ORDER FLOW

The Securities and Exchange Commission, in Rule 11Ac-1-6, requires Cohen & Company to publicly report each quarter on its routing of non-directed orders in securities.

Order Routing Information

RBC Correspondent Services (RBC CS), a division of RBC Capital Markets Corporation — To read on online summary of Cohen & Company execution data for accounts held at RBC Dain Rauscher, click here:
https://www.tagaudit.com/rule6.asp?user=dcsd

Also, Cohen & Company must disclose information each quarter relating to execution practices, including:

The relationship Cohen & Company has with the market centers to send orders. Cohen & Company fully discloses its securities business cleared through RBC Dain.
The market internalization or payment for order flow arrangements with the market centers. Cohen & Company receives no compensation for order flow from RBC Dain, or any market maker.
Cohen & Company may direct a portion of its order flow to market centers, which are done in an effort to obtain best execution for our clients. Cohen & Company receives no compensation for this activity.

PATRIOT ACT DISCLOSURE
IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT OR ESTABLISHING A NEW CUSTOMER RELATIONSHIP

To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions to obtain, verify, and record information that identifies each individual or institution that opens an account or establishes a customer relationship with Cohen & Company Capital Markets.

What this means: If you enter into a new customer relationship with Cohen & Company Capital Markets, the Firm will ask for your name, address, date of birth (as applicable), and other identification information. This information will be used to verify your identity. As appropriate, the Firm may, in its discretion, ask for additional documentation or information. If all required documentation or information is not provided, Cohen & Company Capital Markets may be unable to open an account or establish a relationship with you.

Cohen & Company BUSINESS CONTINUITY PLANNING

Cohen & Company is committed to providing reliable, trustworthy service that represents the best interests of our clients. The firm has developed a business continuity plan to protect our clients and employees in the event of an emergency or significant business disruption. The plan is designed to help prepare for securing employees’ safety and firm property, making financial and operational assessments, promptly recovering and resuming operations, protecting the firm’s books and records, and allowing our clients access to their funds and securities.

If after a significant business disruption you cannot contact us as you usually do at 800·826·6096, you should call our alternative number (215·701·9555) or go to our web site at www.ifmi.com. If you cannot access us through either of those means, you should contact our clearing firm, RBC Dain Rauscher, at 866·358·2729 (www.RBCDainCS.com) for instructions on how it may provide prompt access to your funds and securities, enter orders and process trade-related, cash, and security transfer transactions for your account.

The business continuity plan considers various scenarios that range in severity from a firm- or building-only disruption to an emergency situation on a local or regional level. For example, in the event any Cohen & Company office locations are inaccessible, alternative locations are established and prepared to facilitate business operations. Regardless of whether the disruption affects our building only or is local or regional, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site (www.ifmi.com) or our customer emergency number (215·701·9635). If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

The firm has redundancies in place for its business-critical systems and believes that it can usually be able to resume business within the same day as the disruption. Our goal in all situations is to return to normal business conditions as soon as possible, with minimal impact on our clients and employees. Even in an extreme situation where continuing business may not be possible or practical, Cohen & Company has plans in place that provide clients with access to their funds.

Cohen & Company business continuity plan is subject to change at any time without notice. However, notwithstanding the above, Cohen & Company does not guarantee that for every disaster or business disruption, such plans will be successfully implemented or that such plans will be sufficient and appropriate to avoid, deter or mitigate the disaster or business disruption.

PRIVACY POLICY

We Are Committed to Protecting Your Personal Information
At Cohen & Company, we strive to provide you with the highest level of service and quality of products. In that regard, the privacy of the information you provide to us is important and we want to assure you that we are committed to protecting your privacy.

This Privacy Statement outlines the types of information we gather about you, how we use it and with whom we might share it. We urge you to read this Privacy Notice so that you will understand our commitment to you and to your privacy.

The Types of Personal Information We Collect
In order to provide you with the highest level of service possible, it is necessary for us to collect and maintain certain personal information about you. We collect this information from applications and other forms, from your dealings with us and others and, depending upon the services and products you have requested or for which we have been asked to provide, we may also receive information from consumer reporting agencies and other sources such as our website.

The types of information we collect and maintain may include:

Information contained in applications and other forms including, your name, address, social security number, family member information, beneficiaries, assets and income;
Information concerning your relationships with us such as products or services purchased from us, account balances and transactions and payment history;
Information from consumer reporting agencies such as credit relationships and related history.

How Personal Information is Used
We use personal information in ways that are compatible with the purposes for which we originally requested it. Cohen & Company may use your personal information for the purpose of processing your requests and transactions, offering or furnishing additional products and services or to evaluate your financial needs. Cohen & Company does not share your personal information with unaffiliated Companies except as provided in this Notice.

Cohen & Company will only grant access to your personal information to those employees who have a business purpose for accessing such information. In that regard, we have implemented certain physical, electronic and procedural safeguards to ensure that access to personal information is limited to the appropriate employees. Moreover, Cohen & Company requires its employees to protect your personal information and keep it confidential.

In order to provide you with the appropriate level of service, we may share account and transactional information within Cohen & Company We may also share personal information described above with firms that assist us in carrying out your needs. For example, we may share your personal information for specific business purposes with the following companies:

Financial service institutions, such as mutual fund companies, securities brokers, and banks, with whom we have joint marketing agreements, or
Companies under contract to perform services for us or on our behalf (such as vendors providing data processing, computer software maintenance and development, transaction processing and marketing services.)

Be assured that Cohen & Company does not sell personal information to anyone. Additionally, we treat the personal information of our former clients in the same manner as we treat the personal information of our current clients.

We also reserve the right to disclose your personal information in certain circumstances where we feel that disclosure is required by law, to assist law enforcement officials or officials of regulatory agencies, to perform credit checks or collect monies owed to us, and to protect our rights and property.

The Accuracy of My Personal Information

At Cohen & Company, our goal is to maintain current and accurate information about you in order to properly service your needs. Consequently, Cohen & Company clients can have reasonable access to their personal information to verify the accuracy of this information. You may either write or call your Cohen & Company representative to request your personal account information. If you identify any error in your personal information or you would like to update your records, please advise your Cohen & Company representative.

Thank you and we appreciate your business.