Notice Of Privacy Practices
Herndon Plant Oakley Ltd. and its affiliates
American Investment Services
Herndon Plant Oakley Ltd., Registered Investment Advisor
Herndon Plant Oakley, Ltd. respects your right to privacy. We have always been committed to secure the confidentiality and integrity of your personal information. We are proud of our privacy practices and want our current and prospective customers to understand what information we collect and how we use it.
Why We Collect Your Information
We gather information about you and your accounts so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the products and services we offer and (iii) comply with the laws and regulations that govern us.
What Information We Collect
We may collect the following types of ‘nonpublic personal information’ about you:
- Information about your identity, such as your name, address and social security number
- Information about your transactions with us
- Information we receive from you on applications, such as your beneficiaries or income.
What Sources We Obtain Your Information
We collect nonpublic personal information about Herndon Plant Oakley, Ltd. clients such as you from the following sources:
- Information we receive from you on applications or other forms
- Information about your transactions with us, our affiliates, or others, and
- If you visit our web site, information we collect via a web server, often referred to as a “cookie.” Cookies indicate where a site visitor has been online and what has been viewed
What Information We Disclose
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except to affiliates, as permitted or required by law, or for regulatory compliance. Moreover, we will not release information about our customers or former customers unless one of the following conditions is met:
- We receive your prior written consent
- We believe the recipient to be you or your authorized representative
- We are required by law to release information to the recipient
We only use information about you and your account to help us better serve your investment needs or to suggest services or educational materials that may be of interest to you.
Confidentiality And Security
We maintain physical, electronic and procedural safeguards to guard your personal account information. To further protect your privacy, our website uses the highest levels of Internet security, including data encryption, user names and passwords, and other tools. We also restrict access to your personal and financial data to authorized Herndon Plant Oakley, Ltd. associates who have a need for these records. We require all nonaffiliated organizations to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.
We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.
June 2011
SEC-REQUIRED DISCLOSURE: Report on Routing of Customer Orders
Herndon Plant Oakley Ltd (HPO) has provided information pursuant to a U.S. Securities and Exchange Commission rule (11Ac1-6) that requires firms to make publicly available, quarterly reports on the firm’s order routing practices. The report provides information on the routing of “non-directed orders” which is generally defined as any order that the client has not specifically instructed to be routed to a particular venue for execution.
The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on The Nasdaq Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options.
For each section, this report identifies the venues most often selected by our clearing firm, Wells Fargo Clearing Services, LLC (WFCS), sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of WFCS’s relationship with the venues.
When you select this link you will be leaving the HPO Web site.
https://www.firstclearingllc.com/disclosures/order-routing.htm
Business Continuity Plan Client Disclosure Statement
Herndon Plant Oakley, Ltd. 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 1-800-888-4894 or bragan@216.38.55.225, you should call our alternative number 512-386-1088 or go to our web site at www.hpo.com. If you cannot access us through either of those means, you should contact our clearing firm, Wells Fargo Clearing Services, LLC., at 877-496-3223 or https://www.wellsfargoclearingservicesllc.com/index.htm for instructions on how it may provide custody services, order execution, order comparison, order allocation, access to customer funds and securities, and clearance and settlement services.
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.
Business Continuity Plan Client Disclosure Statement
Herndon Plant Oakley, Ltd. 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 1-800-888-4894 or bragan@216.38.55.225, you should call our alternative number 512-386-1088 or go to our web site at www.hpo.com. If you cannot access us through either of those means, you should contact our clearing firm, First Clearing Correspondent Services., at 877-496-3223 or http://www.firstclearingllc.com/index.htm for instructions on how it may provide custody services, order execution, order comparison, order allocation, access to customer funds and securities, and clearance and settlement services.
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, Wells Fargo Clearing Services, LLC, backs up 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 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 in a timely manner. 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 expect to recover and resume business within 24 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 recover and resume business within 24 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.hpo.com or our customer emergency number, 512-386-1088 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.
If you have questions about our business continuity planning, you can contact us at 1-800-888-4894.
This plan is subject to modification, an updated summary will be promptly posted on our Web site and customers may alternatively obtain updated summaries by requesting a written copy by mail.
Last Updated: November, 2015