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Merchant Banking

Privacy Policy

Our commitment to you

In your relationship with Burrill Merchant Bank, either as an existing or prospective client, you may entrust us with your personal and financial data. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interest. Because your firm’s business and financial information is private, we hold ourselves to the highest standards in its safekeeping and use.

We may collect nonpublic information about your firm from the following sources:

Information we receive from your initial client agreement.

Information about your transactions with us, our affiliates, or others, such as your investment activity or transaction information.

Information about your firm from regulatory authorities.

We protect your firm’s information

We use the information described above to provide the best possible service. We may disclose nonpublic firm information to complete a transaction that you request or authorize, or as otherwise required or permitted by the laws and industry standards that apply to us (e.g. anti-money laundering, regulatory requests). We restrict access to nonpublic personal information about your firm to employees who need to access the information in order to accommodate client requests or regulatory inquiries. We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information.

Our privacy policies and practices will continue to apply to your information even if your account is no longer active.

What you can do

For your protection, we recommend that you do not provide your account information to anyone. If you become aware of any suspicious activity relating to your account, please contact us immediately.

We will keep you informed

You may receive notices of changes to our privacy policies or periodic updates of this notice, as required by law. At Burrill Merchant Bank we are proud of the trust and confidence we have earned from you. We will continue to earn that trust and confidence by keeping your nonpublic personal information secure and confidential.

Business Continuity and Contingency Planning

Securities Industry regulations require that brokerage firms inform their clients of their plans to address the possibility of a business disruption that potentially results from power outages, natural disasters, or other events. Burrill has a comprehensive business continuity program in place, which we review, update and test on a regular basis. The plan provides for continuation of client service within minutes in most cases.

Here are a few examples of what might occur if we were to experience a business disruption of varying magnitude:

If our telephone service were to become unavailable for any reason, we would   

re-route calls through cellular connections until the main lines were restored.

In the event that our primary data storage system became unavailable for any reason, we would transition to a separate back-up location we maintain on a separate power grid and physical location.

If we had a power outage at the firm’s sole office, we would re-route telephone and electronic communications to an alternate location for the duration of the outage.

While no contingency plan can eliminate all risk of service interruption or temporarily impeded account access, we continually assess and update our plans to mitigate all reasonable risk.

Information pursuant to SEC Rule 606 (formerly 11Ac1-6)

Pursuant to SEC Rule 606, Penson Financial Services, Inc. is required to make publicly available a quarterly report with regard to its routing of non-directed orders. For the purpose of this Rule, we have entered into an agreement with Quantum5 Market Surveillance (a Division of S3 Matching Technologies ) to disclose all required information pertaining to this rule. This information can be accessed on the internet at: , or a written copy will be furnished at no cost upon request via telephone to 214-765-1009 or email to

SEC Rule 606(b) requires a broker-dealer to disclose to its customers, upon request, “the identity of the venue to which the customer’s orders were routed for execution in the six months prior to the request, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, that resulted from such orders.