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JMP Securities LLC is an affiliated company and subsidiary of JMP Group Inc., a full-service investment banking and asset management firm that provides investment banking, sales and trading, and equity research services to corporate and institutional clients and alternative asset management products to institutional and high-net-worth investors. JMP Group operates through three subsidiaries, JMP Securities, JMP Credit Corporation and Harvest Capital Strategies. JMP Group is listed on the New York Stock Exchange and trades under the symbol "JMP."
Investment Protection Principles and Research Analysts' Conflict of Interest Policies
Pursuant to NASD Rule 2711 and other initiatives stemming from the New York State Attorney General Eliot Spitzer's agreement with Merrill Lynch & Co. ("the Merrill Lynch principles"), effective July 1, 2002, JMP Securities has amended or reaffirmed its policies related to Research Analysts. Following are excerpts from our Written Supervisory Procedures that address the Merrill Lynch principles:
No JMP research analyst may be subject to the supervision or control of any employee of JMP's Investment Banking Department. Our Research Department reports to the Managing Director with overall management responsibility for the Research Department (the "Research Department Manager"). In turn, the Research Department Manager reports to the Executive Committee. Currently, there are two members of the Executive Committee who are in the Investment Banking Department, however, they do not exercise any direct control over any employee of the Research Department.
JMP will not pay any research analyst any bonus, salary or other form of compensation that is based upon a specific investment banking transaction. JMP's analysts' compensation shall be based upon several factors. Chiefly among such factors is the quality of the research and financial advice provided to our institutional customers and the impact that the analysts' research has on the success of JMP's overall business. Such success may be measured by the overall commissions and fees that our institutional customers pay JMP, as well as the overall number of times JMP is selected by its corporate customers to render advisory, underwriting and other financial services to them. The final compensation is decided by the JMP Compensation Committee consistent with NASD Conduct Rule 2711(d). If any member of the Compensation Committee is part of the Investment Banking Department, such a member will abstain from rendering any opinions regarding Research Analysts.
JMP and its employees are prohibited from offering, directly or indirectly, favorable research, a specific rating or a specific price target, or threatening to change research, a rating or a price target, to a company as consideration or inducement for the receipt of business or compensation. As such, any reason to publish research, other than our professional obligation to provide good advice to our institutional customers, is against our policies and in violation of the Rule. In the event that JMP decides to drop coverage of a company, a final note will be published outlining the reasons. JMP's Director of Research will review and approve all research recommendations to ensure adherence to this policy, while the Director of Compliance will review all research to ensure adherence to the Rules.
Research Report Disclosures. JMP must disclose in research reports if:
(i) the research analyst principally responsible for preparation of the report received compensation that is based upon (among other factors) the member's investment banking revenues;
(ii) JMP or its affiliates managed or co-managed a public offering of securities for the subject company in the past 12 months;
(iii) JMP or its affiliates received compensation for investment banking services from the subject company in the past 12 months; or
(iv) JMP expects to receive or intends to seek compensation for investment banking services from the subject company in the next three months.
Public Appearance Disclosures. JMP research analysts must disclose in public appearances if they know or have reason to know that the subject company is a client of JMP or its affiliates.
The Compliance Manager shall attest annually to the NASD that JMP has adopted and implemented the aforementioned procedures.
SEC Rule 605
In compliance with SEC Rule 605, order execution information can be accessed by clicking the link below.
SEC Rule 606
In compliance with SEC Rule 606 the information for the routing
of customer orders, can be accessed by clicking the link below.
National Instrument 24-101 Trade Matching and Settlement
Institutional trade matching statement endorsed by the Canadian Capital Markets Association.
Payment for Order Flow
JMP Securities does not engage in any agreements for payment for
routing order flow to or receiving order flow from any designated exchanges,
market makers, broker dealers or market centers. Nor does it engage
in any other arrangements that are required to be disclosed as defined
in SEC rule 10b-10(d)(9).
Extended Hours Trading Risk Disclosure
Pursuant to both FINRA and NASDAQ rules, JMP Securities is required to provide the following disclosures regarding risk associated with customer trading in the Pre-Market and Post-Market Sessions:
1. 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 with 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.
Material, Non-Public Information
JMP Securities has policies and procedures in place reasonably designed
to prevent the unauthorized use and disclosure of material, non-public
information about securities issuers, pending research reports and other
confidential data. We believe that these policies ensure that all
information that we provide to others is done so appropriately and in
accordance with all applicable laws, rules and regulations.
Privacy Notice
In accordance with the Federal Financial Privacy Law (Gramm-Leach-Bliley
Act, Nov. 1999), the following are JMP's policies applicable to this website
and to our business relation in general:
Collecting Information
In the course of our relationship with you, we receive or develop information
about you necessary to better service your account and your financial
needs. This information may include: information you provide to us orally
or on applications or other forms; information we develop about you in
the course of providing our services to you, such as your account balance(s),
the assets that we manage and transactions we place on your behalf; technical
information we gather through your access to our website.
Protecting the Information
As a general rule, JMP does not sell, share or otherwise disclose this
private information with others unless such sharing of information is
necessary to provide our services to you. For instance, there may be sharing
of information between the two subsidiaries of JMP, where each subsidiary
is rendering a service to a customer common to both. Further, we share
information with certain third parties, such as our clearing agent, custodian,
attorneys and auditors who, in the ordinary course of providing their
services to us, may require access to information containing your non-public
personal information. In addition, we may disclose your non-public personal
information to others with your consent, where required by law or judicial
process (such as a court order), or otherwise to the extent permitted
under the Federal Financial Privacy Law.
Keeping the Information Secure is a Priority
We restrict access to your non-public personal information to those associates
who need to know that information to provide services to you. Where we
are not comfortable that a service provider is already bound by duties
of confidentiality (i.e. attorneys and auditors), we will require contractual
assurances that it will maintain the confidentiality of any of the information
it obtains from us. In addition, we maintain physical, electronic and
procedural safeguards to protect your non-public personal information.
We continually assess new technology and upgrade our system when appropriate
to better protect information.
If you have any questions about our practices with respect to your non-public
personal information, you may write to us at 600 Montgomery Street, Suite 1100, San Francisco, CA 94111 or call us at (877) 263-1333.
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600 Montgomery Street
Suite 1100
San Francisco, CA 94111
(415) 835-8900 Tel
(415) 835-8910 Fax
(877) 263-1333 Toll-Free
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JMP Securities Rule 606 routing
information