TRADING ABOUT US AFFILIATES Business & Regulatory Contact Us Business & Regulatory After-Hours Trading Risk Disclosure Anti-Money Laundering Policy Business Continuity Plan CIP & Reg S-P Notice Copyrights & Trademarks Disclosures Investor Education and Protection Notice Regarding the NFA’s BASIC System Payment for Order Flow NMS rule 607 Privacy Policy SEC Rule 606 Third-Party Research Disclosures Securities Investor Protection Corp. William O’Neil Securities, a broker/dealer, is a strictly regulated entity. As such, the company adopts policies to comply with all rules and requirements that are relevant to our business. After-Hours Trading Risk Disclosure Pursuant to both FINRA and NASDAQ rules, William O’Neil Securities is required to provide the following disclosures regarding risk associated with customer trading in the Pre-Market and Post-Market Sessions: Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all. Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular markets hours. Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening of the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours. Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system. Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security. Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security. Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (“IIV”). For certain Derivative Securities Products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals. Back to Top Anti-Money Laundering Policy William O’Neil Securities, as an Institutional Brokerage Firm, has a responsibility and a commitment to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. To fulfill this goal we have implemented a specific, comprehensive, internal Anti-Money Laundering Policy. Associates of William O’Neil Securities are considered members of the William O’Neil Securities team, and individually share in the responsibility of fulfilling this commitment. To that end, all William O’Neil Securities associates are apprised of this policy so even those who don’t trade understand our obligations. What is Money Laundering? Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages: (1) cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions; (2) at the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin; and (3) at the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes. The Regulations On October 26, 2001, President George W. Bush signed into law the USA PATRIOT Act, which, among other things, strengthens the anti-money laundering provisions put into place by earlier legislation and includes new anti-money laundering provisions that are applicable to broker/dealers. 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 all financial institutions to obtain, verify, and record information that identifies each person and or institution who opens an account. What this means for you: When you open an account, we will ask for your Institutional name, address, and other information that will allow us to identify the company. We may also ask to see other identifying documents other than those noted previously as needed. Back to Top Business Continuity Plan Last Update: May 2020 Emergency Response Line: (866) 308-2911 (toll free) Firm Policy: William O’Neil Securities’ policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of William O’Neil Securities’ books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities. At this time: There are no disruptions and operations are normal. Please direct any inquires to bcpinfo@oneilsecurities.com. Document Downloads: Disclosure Statement Disclosure Statement for Trading and Client Disclosure Matrix Back to Top CIP & Reg S-P Notice Important information you need to know about our account requirements and confidentiality pledge. To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record customer account information. At William O’Neil Securities we collect public and nonpublic information about our institutional clients as specifically mandated for customer identification and verification by the USA PATRIOT ACT, SEC 17a-3 (Books & Records Requirements), NYSE Rule 405 (“Know Your Customer and NASD Conduct Rule 3110.”) This Notice provides you with some answers about William O’Neil Securities’ Customer Identification Program as well as our Privacy Policy as it relates to SEC Regulation S-P. This Notice provides you with some answers about William O’Neil Securities, Incorporated’s Customer Identification Program as well as our Privacy Policy as it relates to SEC Regulation S-P. What types of information will I need to provide? For an institutional account to be opened, William O’Neil Securities is required to record and verify: The name(s) of the person(s) authorized to conduct business on behalf of your organization; Whether or not your organization intends to have associates trade with our equity desk. If your organization does intend to have associates trade with our equity desk, we will need a trading authorization listing those associates and signed by a party authorized to conduct business on behalf of your organization. For your convenience, we have developed fill-in-the blank forms that, if filled in completely and accurately, will satisfy the above requirements. When filling out the form, if any of the specified terms do not apply, please make the necessary changes so that all the information will reflect your organization appropriately, or contact us for help customizing a version that satisfies our requirements and better addresses your organization’s structure; A corporation, partnership, trust or other legal entity must also provide information about its principal place of business and local office(s) with which we have a business relationship, as noted within one of the following documents: certified articles of incorporation, government-issued business license, LLC agreement(s), and partnership or trust agreement(s) as applicable to the organization of the firm. What happens if I don’t provide the information requested or my identity can’t be verified? If the above information is not provided or your organization’s identity cannot be verified, William O’Neil Securities will be unable to open an account or carry out transactions for your organization, and consequently any already existing accounts may have to be closed. If you have not yet done so, please contact us to provide any of the necessary information noted above. What is William O’Neil Securities’ Privacy Policy? Equally important to our firm and to our clients is our Privacy Policy. William O’Neil Securities' Privacy Policy is located here. Back to Top Copyrights & Trademarks All content on this site, except where otherwise stated, is the sole property of William O’Neil Securities and is protected by copyright and trademark laws. All copyrights and trademarks used herein are the exclusive property of their respective owners and may not be used in any way without written consent of owner. ©2020 O’Neil Securities, Inc. d/b/a William O’Neil Securities. All rights reserved. You may not copy, modify, redistribute, or display any material herein, without the prior written consent of William O’Neil Securities. William O’Neil Securities and its licensors expressly disclaim any express or implied warranties or representations regarding the accuracy, completeness, timeliness, or reliability of information, facts, views, opinions or recommendations contained in this publication. These materials shall not be deemed to be giving investment advice, or advocating the purchase or sale of any security or investment and nothing contained herein is to be construed as a recommendation to buy or sell any securities. Back to Top Disclosures No Investment Banking or Market Making William O’Neil Securities and its affiliates do not engage in investment banking and do not make a market in any securities. Neither William O’Neil Securities nor any of its affiliates have, during the past 12 months, received any compensation from any of the companies discussed in the third party research reports distributed by William O’Neil Securities. None of the companies discussed in such reports are, or have been during the past 12 months, clients of William O’Neil Securities or its affiliates. Held/Not Held All orders received by William O’Neil Securities must be marked as “held”, meaning that William O’Neil Securities will execute your order at the earliest possible time, or “not held”, meaning that William O’Neil Securities has time and price discretion over the order on the day it is entered. Orders that are received without a “held” or “not held” designation will be marked and executed as “not held” by William O’Neil Securities “Not Held” orders give the Firm the flexibility and discretion to act in your best interest by working your orders to obtain the best possible price. Proprietary Positions William O’Neil Securities does not maintain proprietary positions in any securities. Employees of William O’Neil Securities and/or affiliates may now or in the future own positions in the companies discussed in the third party research reports distributed by William O’Neil Securities. As of the end of the month immediately preceding the date of publication of such reports, none of such employees or affiliates beneficially owned 1% or more of the common equity securities of any of the companies discussed in such reports. Options Disclosure Document Pursuant to SEC Rule 9b-1 and various exchange rules, William O’Neil Securities (ONS) is required to provide all clients who trade options or who receive options-related sales materials, a current copy of the Options Disclosure Document (“ODD”) including supplements, issued by the Options Clearing Corporation. A copy of the ODD can be found here: http://www.theocc.com/about/publications/character-risks.jsp General Disclosures General Communication Disclaimer The information contained herein is not and should not be construed as an offer to sell or the solicitation of an offer to buy or sell any securities. Any equity ideas noted herein are not, and should not be construed as a recommendation or rating to buy, hold or sell any security. The information set forth above has been obtained from sources that we believe to be reliable; however no guarantee is made or implied with respect to its accuracy or completeness. The information and content herein are subject to change without notice and William O’Neil Securities, Incorporated, its parent company, affiliates, subsidiaries, employees, officers, agents, or representatives may from time to time have long or short positions or may acquire a direct or indirect beneficial interest in securities mentioned in this communication. External Instant Message Disclaimer Institutional orders are not accepted via Instant Messaging until confirmed by a William O’Neil Securities trader. Instant messages are intended to be received by the named party. In the course of servicing our clients’ need for market and trade information, O’Neil Traders may communicate market and/or stock information consistent with normal business practices and based upon individual client expectations for such. The market and/or stock information should not be construed as an offer to sell or the solicitation of an offer to buy or sell any securities, nor should any stocks mentioned be construed as a recommendation or rating to buy, hold or sell any security. The O’Neil Trader sending the information, or its parent company, affiliates, subsidiaries, officers, employees, agents or representatives may from time to time have long or short positions or may acquire a direct or indirect beneficial interest in securities mentioned in such communications. Transmission Errors Communications may contain confidential, proprietary or legally privileged information. No confidentiality or privilege is waived or lost by any transmission errors. Message transmission is not guaranteed to be secure. If you receive a message in error, please immediately delete it and all copies of it from your system, destroy any hard copies of it and notify the sender. You must not, directly or indirectly, use, disclose, distribute, print, or copy any part of such message if you are not the intended recipient. Compliance Controls Communication Review – William O’Neil Securities monitors and records all communications. We reserve the right to audit and review all correspondence for compliance purposes. Trade Review – William O’Neil Securities has in place appropriate governance policy to address the potential for conflicts of interest and enforces such with dedicated procedures to closely monitor personal trading. Questions regarding William O’Neil Securities' Compliance Controls should be directed to compliance@oneilsecurities.com Back to Top Investor Education and Protection 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. Back to Top Notice Regarding the NFA’s BASIC System William O’Neil Securities (ONS) is required to inform its customers of the National Futures Association (“NFA”) Background Affiliation Status Information Center (“BASIC”). The BASIC system compiles various information on registrants and anyone can access this system on the Internet. The information in the BASIC system includes Commodity Futures Trading Commission (“CFTC”) registration information and membership information from the NFA. Additionally, regulatory and non-regulatory actions contributed by the NFA, the CFTC and U.S. futures exchanges regarding futures-related activity are included. The NFA BASIC system may be accessed at http://www.nfa.futures.org/basicnet/. To locate information on a registrant, simply enter the registrant’s NFA ID number when prompted. For questions regarding this system, you may contact the NFA information center at 1-800-621-3570 between the hours of 8:00 a.m. to 5:00 p.m. CST. Back to Top Payment for Order Flow NMS rule 607 William O’Neil Securities (ONS) has no payment for order flow relationship with any broker-dealers or third-party execution providers. However, ONS routes orders to market centers, including national securities exchanges, alternative trading systems, and electronic communications networks that may offer credits for orders that provide liquidity and may assess fees for orders that take liquidity. Routing decisions for an order are based upon ONS’ responsibility of seeking to provide best execution to clients. Back to Top Privacy Policy William O’Neil Securities maintains the following Privacy Statement to protect the personal information you provide online. We will not sell your personal information to any non-affiliated third party, for any reason, at any time. William O’Neil Securities’ Privacy Statement is located here. The Privacy Statement details all personal information we may collect from you, how we use it, and how we may share it. For residents of the European Union, please review William O’Neil Securities’ European Data Privacy Addendum, which is included within the Privacy Statement. Large Trader Rule In accordance with Securities Exchange Act Rule 13h-1, market participants that conduct a substantial amount of trading activity are required to file Form 13H in order to identify themselves as a “large trader” to the SEC. The SEC assigns a large trader identification number that must be provided to the participants registered broker-dealers. Broker-dealers are then required to maintain records, including large trader transaction times, which may be required upon the request of the SEC. Back to Top SEC Rule 606 For the Most Recent Available Quarter William O’Neil Securities is presenting this information pursuant to the U.S. Securities and Exchange Commission Rule 11Ac1-6 requiring all brokerage firms to make publicly available quarterly reports that present a general overview of their order routing practices. The report provides information on the routing of “non-directed orders” — any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, William O’Neil Securities has selected the execution venue on behalf of its customers in compliance with best execution practices. The report is divided into the following sections: New York Stock Exchange listed securities, stocks listed on The NASDAQ Stock Market, and American Stock Exchange or regional exchange listed securities. The information is further divided into three categories: Market, Limit, and Other. As outlined by the SEC in guidance to brokerage firms, “market-not-held” orders fall under the “Other” category, as would short sale orders. While William O’Neil Securities deals exclusively with institutional clients whose orders are not-held, limit orders are segregated for this report and fall under the “Limit” category. For each section, the report identifies the significant venues to which customer orders were routed for execution during the most recent quarter available, and discloses that William O’Neil Securities (ONS) has no payment for order flow relationship with any broker-dealers or third-party execution providers. However, ONS routes orders to market centers, including national securities exchanges, alternative trading systems, and electronic communications networks that may offer credits for orders that provide liquidity and may assess fees for orders that take liquidity. Routing decisions for an order are based upon ONS’ responsibility of seeking to provide best execution to clients. In accordance with the Rule, these reports will be posted on this Web site, which is publicly available, within one month following the end of the previous quarter. In addition, a printed copy of this quarterly report will be furnished upon request. Click here for the most recent order routing report. In addition, upon written request, ONS will provide: The venue to which the order was routed for execution at any time six months prior to the request; Whether the order was directed or non-directed; and The time of the execution that resulted from such order. Lawrence G Martel, CCO compliance@oneilsecurities.com 617.936.8584 Back to Top Third-Party Research Disclosures This report has been produced by William O’Neil + Co., Incorporated (“William O’Neil + Company”), a registered investment adviser, and is being distributed as 3rd party research by William O’Neil Securities. William O’Neil + Company and William O’Neil Securities are affiliated companies. In connection with the distribution of this report and under FINRA Rule 2241 (h)(4) and Notice to Members 15-30, William O’Neil Securities has no disclosures to declare specific to the subject company or companies. General Disclaimers Research provided in the attached report was prepared by William O’Neil + Company and its analyst(s) identified on the attached report. William O’Neil Securities did not assist in the preparation of the accompanying report, and its accuracy and completeness are not guaranteed. The attached report is distributed solely for information purposes and is not a solicitation or an offer to buy any security or instrument or to participate in any trading strategy. The investment discussed may not be suitable for all investors. Investors must make their own decisions based on their specific investment objectives and financial circumstances. The research provided by William O’Neil + Company may have been made available to customers of William O’Neil + Company before being made available to William O’Neil Securities. Any opinions expressed or implied herein are not necessarily the same as those of William O’Neil Securities. Back to Top Securities Investor Protection Corp. All customers are advised that information about SIPC, including the SIPC brochure How SIPC Protects You, may be obtained by contacting SIPC by phone, email, or regular mail: Securities Investor Protection Corporation 805 15th Street, N.W. Suite 800 Washington, D.C. 20005-2215 Tel: (202) 371-8300 Fax: (202) 371-6728 Email: asksipc@sipc.org For more detailed information please visit the SIPC website at www.sipc.org. Back to Top CONTACT US | SITE MAP | CAREERS | TERMS OF USE AML Policy | BCP | CIP & Reg S-P Privacy Notice | Disclosures | Privacy Policy | SEC 606 © 2021 O’Neil Securities, Inc. d/b/a William O’Neil Securities. All rights reserved. The services on this site are provided by William O'Neil Securities, members of FINRA, NYSE and SIPC. This site is for informational purposes only. Nothing contained herein constitutes an offer on our part to sell or a solicitation to purchase any securities, nor should any information contained herein be construed as investment advice or a recommendation to buy, hold or sell any securities. Offers can only be made and transactions in securities may only be effected where lawful under applicable law. Representatives of William O'Neil Securities may only transact business in states in which they are appropriately registered or exempt from registration. Check the background on the firm at FINRA's Brokercheck.