2021 Qualified Counterparty General Disclosures

Dear Valued Counterparty,

Old Mission Markets LLC (“OMM”) believes it’s necessary to make certain disclosures to you and remind you of certain SEC, FINRA, and SRO regulations and policies important to OMM.

Anti-Money Laundering Notice
OMM recognizes the importance of deterring terrorist and money laundering activities, as well as the strategic importance of protecting its reputation from exposure to illegal activities perpetrated by third parties. The Firm has, therefore, developed a policy to assist in the recognition, detection and prevention of money laundering in connection with its securities business.

OMM is committed to ensuring that its facilities are not used in any manner to support, aid or abet terrorist or criminal activity or money laundering. OMM is further committed to comply with all laws and regulations designed to combat money laundering activities, including those rules and regulations requiring broker-dealers to report transactions involving currency, certain monetary instruments and suspicious activity. Every OMM principal, employee, supervisor, and associated person plays a part in protecting the firm from money launderers and other criminal activities.

Accordingly, OMM has adopted robust procedures to ensure that it satisfies this commitment and to ensure that it complies with its statutory and regulatory obligations in this regard, including its compliance with the USA PATRIOT Act of 2001.

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 or entity that opens an account.

OMM may request information and documents that will allow us to identify you, your firm and your authorized representatives. A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government‐issued business license, a partnership agreement or a trust agreement.

Business Continuity
OMM has developed and implemented a robust Business Continuity Plan (BCP) 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 the Firm’s books and records. Key features of the Firm’s BCP include maintenance and annual review of the following:

  • Operational risk involving communication with its clearing firm, counterparties, banks, regulators, and various critical business constituents.
  • Financial and Credit Risk involving the Firm’s ability to determine the value and liquidity of its investments and other assets to evaluate its ability to continue to fund its operations and remain in capital compliance.
  • Mission Critical Systems involving the processing and settlement of securities transactions.

Although no contingency plan can eliminate all risk of service interruption, OMM continually assesses and updates its BCP to mitigate all reasonable risks. As OMM continues to review the Firm’s BCP, and as conditions in our firm and the industry change, we will revise the plan accordingly and as considered necessary.

Ability to Record Telephone Conversations
OMM reserves the right to record telephone conversations at our discretion. Even though you may not hear an audible tone, OMM may record your conversations with our Firm employees for our mutual protection. Your use of the telephone means you agree to this recording policy.

Payment for Order Flow Disclosure
OMM currently has no PFOF (Payment For Order Flow) arrangements in place with exchanges, broker-dealers, dark-pool operators, or ECNs. Should the Firm’s policy regarding PFOF change at any point, your firm will be informed of the arrangement(s) as soon as practicable, but no later than 90 days from the implementation of the arrangement(s).

SIPC / FINRA Disclosure
OMM is a member of the Securities Investor Protection Corporation (“SIPC”), as well as a member of FINRA (CRD# 281867). For more information regarding SIPC, please visit SIPC.org. For organizational details pertaining to OMM, please visit FINRA BrokerCheck @FINRA.org.

Certificates (Membership Required)
Rule 144A Qualified Institutional Buyer and Section 3(c)(7) Qualified Purchaser

Sophisticated Municipal Market Professional Affirmation

SEC Rule 605 – Order Execution
SEC Rule 605 of Regulation NMS requires market centers that trade National Market System (“NMS”) securities to make available to the public monthly electronic reports that include uniform statistical measures of execution quality for covered orders. All institutional client orders handled by OMM are considered “Not Held” orders, outside the scope of covered orders. As a result, OMM currently has no obligation pursuant to Rule 605.

SEC Rule 606 – Order Routing
Rule 606 requires broker-dealers that route customer orders in equities and option securities to publish quarterly reports that provide a general overview of their routing practices. In this report, the venues to which non-directed customer orders in U.S. exchange-listed equity securities and options were routed for execution must be disclosed, as well as the nature of any relationship the broker-dealer has with each venue. The purpose of this report is to provide the public with information on how broker-dealers route orders, enable the evaluation of order routing practices and foster competition among market participants. Upon request, broker-dealers also must disclose to customers the venues to which their individual orders were routed. Each customer may request a written copy of the report be mailed to them at no charge.

OMM is currently not required to post Rule 606 statistics. The Firm is currently within the 6-month requirement to aggregate routing data prior to posting publicly. Reports will be made available immediately after the expiration of the 6-month statistics accrual.

Material Aspects of Relationship with Route Venues
OMM is an affiliate of Exchange Member Old Mission Capital LLC (“OMC”). OMC is a registered and bona-fide market maker on multiple exchanges and ECNs. At its discretion, OMM may “internalize” non-directed institutional client orders in which OMC makes a market. OMC could sustain profits or losses by trading as principal with any internalized institutional client orders.

Reference Price Trades
Old Mission Markets LLC and its affiliates, including Old Mission Capital LLC, (collectively, “Old Mission”, or “the Firm”, or “we”) engage in principal trading and market making, where institutional client services are provided solely through Old Mission Markets LLC, an SEC-registered broker-dealer and FINRA member.

Old Mission may agree to facilitate a guaranteed reference price trade as principal at a committed price relative to an applicable reference such as VWAP, NAV, or open or closing price. Institutional order flow of this nature is generally known as GVWAPs (Guaranteed Volume Weighted Average Price), or guaranteed reference price trades. Once committed to facilitate such institutional client orders, Old Mission will likely continue to function as a bona-fide market maker in the security, trade the security as principal for risk management purposes, facilitate GVWAP orders for other institutional clients, or a variety of other reasons. Trading in this capacity creates the potential to adversely impact the subject reference price. Old Mission will make every effort to limit the level of impact from such principal trading and risk management.

Institutional Client Complaints
Any Institutional Client who wishes to lodge a complaint related to the order handling activities of any current or former OMM employee may do so in the following manner:

Mail a complaint to:
Old Mission Markets LLC
Attention: Compliance
1 North Dearborn St., 8th floor
Chicago, IL 60602

Contact OMM Compliance:
Phone: 312-260-3052
Email: compliance@oldmissioncapital.com