Business Practice

Customer Identification - Important Information about Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires certain financial institutions, including Cleary Gull Inc. as the introducing broker to your investment account custodied at RBC Correspondent Services, to obtain, verify, and maintain information that identifies each person who opens an account. To meet this federal obligation, we will ask for your name, address, date of birth (for an individual), and an identification number or articles of incorporation that will allow us to verify your identity. We may also ask for a driver's license or other identifying documents. This process may include the use of third party sources to verify the information provided.

For accounts owned by a trust, customer identification procedures may require Cleary Gull to obtain a copy of a trust instrument. Any trust instrument will be retained solely for the purposes of customer identification as required by law, and Cleary Gull accepts no responsibility for the enforcement or administration of any of the terms thereof.

Business Continuity Planning

In accordance with regulations, Cleary Gull Inc. has developed a business continuity plan that is intended to permit us to continue, or quickly recover and resume, critical business operations during natural disasters, power outages, or other significant events. While there can be no assurance that service will continue without interruption in all circumstances, our plan does address the actions that we will take in the event that there is a significant business disruption.

Our plan addresses: 

• data backup and recovery
• 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
• regulator reporting
• assuring clients prompt access to their funds and securities if we are unable to  continue our business
• any entities the firm may rely on for certain procedures and/or mission critical systems

Because our plan contains details of a confidential and proprietary nature, it is not distributed to the public.

Contacting Us: In the event of a significant business disruption, you can obtain up-to-date information regarding the operating status of our firm on this website. In the event you cannot contact us or obtain up-to-date information from this website, you should contact your account custodian who will assist you in accessing your funds and securities and/or processing account transactions.