Business Continuity
CIG Capital Advisors has developed a Business Continuity Plan (BCP) detailing how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will need to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our BCP.
Contacting Us: If you have any questions about our BCP or if after a significant business disruption you cannot contact us at (248) 827-1010 or ClientService@cigcapitaladvisors.com, you should call our alternative number (248) 631-6699 or go to our web site at www.cigcapitaladvisors.com. If you cannot access us through either of those means, you should contact our custodial partner, Schwab Advisor Services at (800) 515-2157 or visit https://advisorservices.schwab.com for instructions on how you may obtain prompt access to funds and securities, enter orders and process other trade-related cash and security transfer transactions.
Our BCP: 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 BCP is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our BCP Addresses: Data backup 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. Charles Schwab & Co., Inc. backs up many of our important records in a geographically separate area. 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 that Schwab’s recovery time objective (RTO) for business resumption, including those involving a relocation of personnel or technology, is four (4) hours or less, depending upon the availability of external resources. Your orders and requests for funds and securities could be delayed during this period.
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 seek to recover and resume business within 6 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and seek to recover and resume business within 12 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and instruct you on how to contact us through our web site www.cigcapitaladvisors.com or our customer emergency number, (248) 631-6699. 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.
Complaints
Complaints can be made by calling the Compliance Department at (248) 827-1010 or by sending a written statement to the following:
CIG Capital Advisors
One Towne Square, Suite 1850
Southfield, Michigan 48076
Attention: Compliance Department
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 CIG’s Customer Identification Program.
What types of information will I need to provide? When you open an account, CIG is required to collect the following information: 1) Name; 2) Date of birth; 3) Address, 4) Identification number, such as a U.S. citizen: taxpayer identification number (Social Security number or employer identification number), a 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 a 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 and objectives and risk tolerance.
What happens if I don’t provide the information requested or my identity can’t be verified? CIG may not be able to open an account or carry out transactions for you. If CIG has already opened an account for you, 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.
Form ADV Offer
Upon request, CIG Asset Management will provide you a copy of Part 2A and the Appendix of our most recent Form ADV, at no cost, which describes the services offered through CIG Asset Management and other important information.
If you wish to receive an update of CIG Asset Management’s Form ADV Part 2A and/or the Appendix, please call our Compliance Department at (248) 827-1010.
Householding
Through a process called householding, Schwab can group your related accounts together for mailing and financial reporting. This offers you added convenience and will not change the frequency or timing of your statements. You will receive a consolidated cover sheet, which includes a combined portfolio value and combined income and distributions for all of your accounts. Attached to this cover sheet will be statements for each of your accounts. Please contact us at (248) 827-1010 if you would like to initiate or cancel householding.
Margin Account Disclosure
Securities purchased on margin are the firm’s collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account. It is important that you fully understand the risks involved in trading securities on margin. These risks include the following: 1) You can lose more funds than you deposit in the margin account; 2) The firm can force the sale of securities or other assets in your account(s); 3) The firm can sell your securities or other assets without contacting you; 4) You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; 5) The firm can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice; and 6) You are not entitled to an extension of time on a margin call.
Payment for Order Flow
Pursuant to SEC Rule 11Ac1-3, CIG Securities, Inc. is required to disclosure its payment for order flow practices to its customers at the time that an account is opened and annually thereafter. CIG does not accept payment for order flow from any broker or dealer, securities exchange, securities association or exchange member to which we route our customers’ orders for execution.
Privacy Notice
CIG Capital Advisors (“CIG”) is the parent company of CIG Securities, Inc. a registered broker-dealer and FINRA/SIPC member, CIG Asset Management, Inc. a SEC Registered Investment Adviser, and CIG Risk Management, Inc. a licensed insurance agency. This notice applies to all CIG affiliated entities.
At CIG, we have worked hard to maintain the highest standards of confidentiality and to respect the privacy of our customer’s personal information. We value the trust of our clients and will continue to recognize the importance of holding your personal financial information as confidential. We are providing you with this Privacy Notice to describe how we collect information about you, under what circumstances we may disclose the information to others, and how we safeguard your information in our possession.
Information we collect about you: The non-public personal information we collect about you (your “information”) comes primarily from the account applications, forms, correspondence and other information you provide to us. We may also obtain information about you from our representatives and from third parties who provide you with financial products or services. In addition, we may collect information about you in compliance with certain laws and regulations.
Our Disclosure Policies: We may disclose information about you to our staff, affiliates, representatives, and third parties who provide you with financial products and services. Third parties may include, but are not limited to, financial service providers such as mutual fund companies, insurance companies, and custodial firms such as Schwab; non-financial companies such as credit reporting agencies; or others with whom you have consented to our sharing of your information. Our privacy policy is the same for current, as well as former customers. If you close your account, in the process of transferring your investments we may share your information with the new broker-dealer or custodian that you select.
We may disclose information such as your name, address, social security number, date of birth, transactional information, or other financial information when necessary for us to provide you with financial products and services or report on your account, or where disclosure is prescribed by law. We do not disclose your information to nonaffiliated companies who intend to market their products to you.
“Opting-out” of Third-Party Disclosures: If you do not want us to share your information (other than as prescribed by law) with any nonaffiliated third parties you may contact our Compliance Department at (248) 827-1010 or by sending a written request to:
CIG Capital Advisors
One Towne Square, Suite 1850
Southfield, MI 48076
Attn: Compliance Department
Securing your Information: Our staff, affiliates, and representatives who have access to your information are required to follow our procedures which have been reasonably designed to keep your information secure and confidential. We restrict access to our staff based on their need to know your information in order to service your account. We maintain physical, electronic, and procedural safeguards that have been designed to protect your information.
Investor Education and Protection
FINRA provides information regarding the disciplinary history of member firms and their associated persons through their BrokerCheck® system at www.finra.org/brokercheck or by calling the BrokerCheck Hotline at (800) 289-9999. Additional information, including a brochure describing their public disclosure program, may be obtained from the FINRA website at www.finra.org.
SIPC Protection
As a member of the Securities Investor Protection Corporation (SIPC) and pursuant to FINRA Rule 2342, CIG Securities, Inc. is required to inform its new and existing clients that they may obtain information about the SIPC by contacting the SIPC. You may obtain information including, but not limited to, the SIPC brochure by phone at (202) 371-8300 or via the SIPC website at www.sipc.org.
MSRB Notifications
CIG Securities, Inc. is a broker/dealer registered with the SEC and the MSRB as well as a FINRA member. As an MSRB regulated entity, CIG Securities would like to direct you to the MSRB website (www.msrb.org) where you can find a library of information and informational brochures pertaining to the municipal securities market.