Legal

Treasury Brokerage maintains the highest legal standards for all of its business practices. Below is a summary of those important topics.

Business Continuity Plan Disclosure

FINRA Rule 3510 requires each member firm to create and maintain a business continuity plan. In accordance with these rules Treasury Brokerage, LLC has developed a plan to ensure that business continues to run uninterrupted during business emergencies.

The plan is designed to address key areas of concern including but not limited to the following:

• Books and records recovery;
• All mission critical systems;
• Financial and operational assessments;
• Alternate means of communication between Treasury Brokerage, LLC and its customers;
• Alternate means of communication between Treasury Brokerage, LLC and its employees;
• Alternate physical locations of employees;
• Critical business constituent, bank and counter-party impact;
• Regulatory reporting;
• Communications with regulators; and
• How Treasury Brokerage, LLC will ensure that all customers have access to their funds and securities in the event Treasury Brokerage, LLC determines it is unable to continue its business.

Events creating a disruption of business may vary in nature. They could affect only Treasury Brokerage, LLC, affect the building where Treasury Brokerage, LLC is located, affect the entire business district where Treasury Brokerage, LLC is located, result in a citywide disruption, or result in a regional disruption. Treasury Brokerage, LLC fully intends to continue to conduct its securities business during these periods of business disruption ranging from disruptions that only affect Treasury Brokerage, LLC to disruptions that have regional impact.

To address disruptions affecting Treasury Brokerage, LLC and the location(s) in which the firm conducts its business, arrangements have been made with organizations and facilities to supply a physical location as well as key technology infrastructure in an area that does not share power grids with the affected location, affording Treasury Brokerage, LLC the opportunity to relocate its key employees and critical information technology systems to provide services for its clients.

To address citywide and regional business disruptions, Treasury Brokerage, LLC has contracted with vendors to supply Treasury Brokerage, LLC alternate office space and access to critical technology in cities and regions that differ from the affected area. Treasury Brokerage, LLC intends to take advantage of this and employ the use of these facilities and affiliates which are located in other cities or regions of the country.

Please be advised that business continuity plans are subject to change and modification. Treasury Brokerage, LLC intends to update and test its business continuity plans as business conditions and technology change.

Should you have any questions concerning our business continuity plan, you may submit a written request for additional information to our Customer Service Department located at 648 Menlo Avenue, Suite 2, Menlo Park, CA 94025.

Customer Identification Program Notice

Important Information You Need to Know About Opening A New Account

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.

This Notice answers some questions about the firm’s Customer Identification Program.

What types of information will I need to provide?

When you open an account, we are required to collect information such as the following from you:

• Your name
• Date of birth
• Address
• Identification number:
  • U.S. Citizen: taxpayer identification number (social security number or employer identification number)
  • Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.

You may also need to show your 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, government-issued business license, a partnership agreement, or trust agreement.

U.S. 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, objectives and risk tolerance.

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

We may not be able to open an account or carry out transactions for you. If we have already opened an account, we may have to close it.

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.

Mutual Funds Breakpoint Discounts Disclosure Statement

Before investing in mutual funds, it is important that you understand the sales charges, expenses, and management fees that you will be charged, as well as the breakpoint discounts to which you may be entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best investment for your particular needs and may help you reduce the costs of your investment. This disclosure document will give you general background information about these charges and discounts. However, sales charges, expenses, management fees, and breakpoint discounts vary from mutual fund to mutual fund. Therefore, you should discuss these issues with your financial advisor and review each mutual fund’s prospectus and statement of additional information, which are available from your financial advisor, to get the specific information regarding the charges and breakpoint discounts associated with a particular mutual fund.

Sales Charges

Investors that purchase mutual funds must make certain choices, including which funds to purchase and which class share is most advantageous. Each mutual fund has a specified investment strategy. You need to consider whether the mutual fund’s investment strategy is compatible with your investment objectives. Additionally, most mutual funds offer different share classes. Although each share class represents a similar interest in the mutual fund’s portfolio, the mutual fund will charge you different fees and expenses depending upon your choice of share class. As a general rule, Class A shares carry a “front-end” sales charge or “load” that is deducted from your investment at the time you buy fund shares. This sales charge is a percentage of your total purchase. As explained below, many mutual funds offer volume discounts to the front-end sales charge assessed on Class A shares at certain predetermined levels of investment, which are called “breakpoint discounts.” In contrast, Class B and C shares usually do not carry any front-end sales charges. Instead, investors that purchase Class B or C shares pay asset-based sales charges, which may be higher than the charges associated with Class A shares. Investors that purchase Class B and C shares may also be required to pay a sales charge known as a contingent deferred sales charge when they sell their shares, depending upon the rules of the particular mutual fund.

Breakpoint Discounts

Most mutual funds offer investors a variety of ways to qualify for breakpoint discounts on the sales charge associated with the purchase of Class A shares. In general, most mutual funds provide breakpoint discounts to investors who make large purchases at one time. The extent of the discount depends upon the size of the purchase. Generally, as the amount of the purchase increases, the percentage used to determine the sales load decreases. In fact, the entire sales charge may be waived for investors that make very large purchases of Class A shares. Mutual fund prospectuses contain tables that illustrate the available breakpoint discounts and the investment levels at which breakpoint discounts apply. Additionally, most mutual funds allow investors to qualify for breakpoint discounts based upon current holdings from prior purchases through “Rights of Accumulation,” and future purchases, based upon “Letters of Intent.” This document provides general information regarding Rights of Accumulation and Letters of Intent. However, mutual funds have different rules regarding the availability of Rights of Accumulation and Letters of Intent. Therefore, you should discuss these issues with your financial advisor and review the mutual fund prospectus to determine the specific terms upon which a mutual fund offers Rights of Accumulation or Letters of Intent.

1. Rights of Accumulation

Many mutual funds allow investors to count the value of previous purchases of the same fund, or another fund within the same fund family, with the value of the current purchase, to qualify for breakpoint discounts. Moreover, mutual funds allow investors to count existing holdings in multiple accounts, such as IRAs or accounts at other broker-dealers, to qualify for breakpoint discounts. Therefore, if you have accounts at other broker-dealers and wish to take advantage of the balances in these accounts to qualify for a breakpoint discount, you must advise your financial advisor about those balances. You may need to provide documentation establishing the holdings in those other accounts to your financial advisor if you wish to rely upon balances in accounts at another firm.

In addition, many mutual funds allows investors to count the value of holdings in accounts of certain related parties, such as spouses or children, to qualify for breakpoint discounts. Each mutual fund has different rules that govern when relatives may rely upon each other’s holdings to qualify for breakpoint discounts. You should consult with your financial advisor or review the mutual fund’s prospectus or statement of additional information to determine what these rules are for the fund family in which you are investing. If you wish to rely upon the holdings of related parties to qualify for a breakpoint discount, you should advise your financial advisor about these accounts. You may need to provide documentation to your financial advisor if you wish to rely upon balances in accounts at another firm.

Mutual funds also follow different rules to determine the value of existing holdings. Some funds use the current net asset value (NAV) of existing investments in determining whether an investor qualifies for a breakpoint discount. However, a small number of funds use the historical cost, which is the cost of the initial purchase, to determine eligibility for breakpoint discounts. If the mutual fund uses historical costs, you may need to provide account records, such as confirmation statements or monthly statements, to qualify for a breakpoint discount based upon previous purchases. You should consult with your financial advisor and review the mutual fund’s prospectus to determine whether the mutual fund uses either NAV or historical costs to determine breakpoint eligibility.

2. Letters of Intent

Most mutual funds allow investors to qualify for breakpoint discounts by signing a Letter of Intent, which commits the investor to purchasing a specified amount of Class A shares within a defined period of time, usually 13 months. For example, if an investor plans to purchase $50,000 worth of Class A shares over a period of 13 months, but each individual purchase would not qualify for a breakpoint discount, the investor could sign a Letter of Intent at the time of the first purchase and receive the breakpoint discount associated with $50,000 investments on the first and all subsequent purchases. Additionally, some funds offer retroactive Letters of Intent that allow investors to rely upon purchases in the recent past to qualify for a breakpoint discount. However, if an investor fails to invest the amount required by the Letter of Intent, the fund is entitled to retroactively deduct the correct sales charges based upon the amount that the investor actually invested. If you intend to make several purchases within a 13 month period, you should consult your financial advisor and the mutual fund prospectus to determine if it would be beneficial for you to sign a Letter of Intent.

As you can see, understanding the availability of breakpoint discounts is important because it may allow you to purchase Class A shares at a lower price. The availability of breakpoint discounts may save you money and may also affect your decision regarding the appropriate share class in which to invest. Therefore, you should discuss the availability of breakpoint discounts with your financial advisor and carefully review the mutual fund prospectus and its statement of additional information, which you can get from your financial advisor, when choosing among the share classes offered by a mutual fund. If you wish to learn more about mutual fund share classes or mutual fund breakpoints, you may wish to review the investor alerts available on the FINRA Web site. See Understanding Mutual Fund Classes at http://www.FINRA.com/mfclasses, and Mutual Fund Breakpoints: A Break Worth Taking at http://www.FINRA.com/breakpoints or visit the many mutual fund Web sites available to the public.

The information and services provided on this Web site are not provided to and may not be used by any person or entity in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules or regulations of any governmental authority or regulatory or self-regulatory organization or clearing organization or where Treasury Brokerage is not authorized to provide such information or services. Some products and services described in this Web site may not be available in all jurisdictions or to all clients. Information contained on the web site or any attachments or links are for institutional use only and is not intended for use or distribution to the general public.

Data presented is provided by other third parties and Treasury Brokerage does not ensure the accuracy of the data nor shall be liable for any damages that result from the use of this data. Amounts and timing for automated trades and wires are determined based on your inputs into the system and on data provided by third-parties. Treasury Curve and its affiliates provide no guarantee as to the accuracy, timeliness or completeness of the balance, transaction detail and performance information, based on third-party data and is not responsible or liable for delays, interruptions, omissions or resulting consequences based on the use of this third-party data. Treasury Brokerage acts as a referring agent and does not handle customer funds. Treasury Brokerage does not endorse or offer recommendations regarding the capabilities, products, or offerings of one Investment Manager, Mutual Fund, Broker-Dealer or Bank over another. Treasury Brokerage assumes that the user will perform their own evaluation of capabilities and qualifications of Investment Manager(s), Mutual Fund(s), and/or Broker-Dealers or Bank whose services the user might engage directly or indirectly through Treasury Brokerage. Although transaction details are immediately issued when future-dated trades are entered, trades are not confirmed until they are processed on the actual date of the transaction. Investments in the Funds are not guaranteed or insured. Past performance is not indicative of future results. While the Funds accessible through Treasurycurve.com seek to maintain the value of your investment at $1.00 per share, it is possible to lose money by investing in these Funds. The prospectus is available via the link to the asset manager on the Research page in the column entitled Fund Company URL. The prospectus contains more complete information about each Fund including distribution fees and expenses. An investor should read the prospectus carefully before investing or sending money. Hypothetical performance (such as back tested results or projected performance) does not reflect the performance of actual accounts and are not intended to serve as a guarantee of future results. Differences in account size, timing of transactions and market conditions prevailing at the time of investment may lead to different results. References to “free” technology refers to the fact that Treasury Brokerage may choose not to charge a subscription fee. Clients should understand that they will still incur additional costs and expenses associated with investing, including the underlying fees and expenses of the funds in which they invest, trading costs and taxable gains/losses associated with their investments. For more complete information, including yields, charges, and expenses, please contact us at (877) 982-8783 or your investment fund directly. Treasury Brokerage is a member of the FINRA/SIPC.

Treasury Brokerage, LLC, and its affiliates, assigns or contractors, may receive compensation from each fund company for which services are rendered. These fees are typically paid from the funds normal operating expenses and do not represent any additional cost to the client. Investor Education and Protection Pursuant to FINRA Rule 2267, please note that the toll-free number for the Public Disclosure Program of FINRA (which provides certain information about the disciplinary history of FINRA members and their associated persons) is 1-800-289- 9999, the FINRA website is www.finra.org and an investor brochure that includes information describing the Public Disclosure Program is available upon request from FINRA.

Securities offered by Treasury Brokerage, LLC a member of FINRA/SIPC.  |  brokercheck.finra.org