Chapter Eight - Supervision

Chapter Eight - Supervision
1.
OUR REGULATOR
SEC:
SEC is the main enforcer of our nation’s securities laws. It oversees our firm directly or indirectly
through the FINRA and various SROs.
FINRA:
Broker-Dealers are subject to the oversight of the FINRA in addition to the SEC. FINRA is a
membership self-regulatory organization (SRO) of securities firms, authorized by an act of
Congress in 1938. FINRA sets the overall strategic direction and policy agendas of the whole
organization oversees the effectiveness of its subsidiaries, and ensures that the organization's
statutory and self-regulatory obligations are fulfilled.
FINRA regulates the securities markets for the ultimate benefit and protection of the investor.
FINRA helps ensure that member firms, like Quest Capital Strategies, Inc., and their employees,
comply with FINRA and Municipal Securities Rulemaking Board (MSRB) rules, as well as
federal and state securities laws and regulations.
STATES:
Each individual state has its own securities laws and rules. These state rules are known as "Blue
Sky Laws". While these laws vary from state to state, the laws require the registration of
securities offerings, and registration of brokers and brokerage firms.
It is a registered representative’s responsibility to comply with all securities laws and rules.
2.
SUPERVISORY DIAGRAM
In order to keep the supervisory list current, we have published the “Responsibility of Principal” list on
line. It will be updated as it is needed. The Chief Compliance Officer (CCO) is the primary supervisor
of the Compliance Department. The CCO is responsible for establishing, maintaining and enforcing a
system of supervisory control policies and procedures of Quest Capital. Updating the firm Supervisory
Procedures Manual, amending the firm back office supervisory procedure, and setting up a system of
training and testing procedures to verify that the firm’s supervisory procedures are adequate, are duties
of the CCO. The CCO may designate other general securities principals to assist the above mentioned
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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responsibilities. However, the CCO is the responsible person and should provide a written report no less
than annually to the CEO regarding the current status and effectiveness of supervisory procedures.
The CEO will have at least one annual meeting with the CCO to discuss the findings of the written
report. The CEO will attest annually that the firm has in place a process to establish, maintain, review,
test, and modify written compliance and supervisory procedures.
The detailed job responsibilities are listed on the Supervisors & Department Personnel. It is the Chief
Compliance Officer’s responsibility to supervise the New Account Department, the Licensing
Department, the Recruiting Department, and the Compliance Department.
The following chart is Quest Capital’s Organizational Chart
Board of Director
President (CEO)
Chief Compliance Officer
Chief Financial Officer
Compliance Officer
Office Manager and
works with CCO
Compliance Inspector
Accounting
New Account
Licensing
Recruiting
Branch Manager
Representatives
Rep at Branch
Office
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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3.
SUPERVISORY PROCEDURE DIAGRAM
Chief Executive Officer
(Rule 3013 Annual Compliance Certification)
Rule 3012 Annual Written Report
Chief Compliance Officer
Compliance Department Review
Chief Financial Officer
Compliance Officer
Supervisor of Each Department
Compliance Inspector
Supervisory Control Procedures
Independent Verification
and Testing
Independent
CPA Annual
Audit
COMREC
Automated
Monitoring
Registered
Branch and
NonRegistered
Office
review
Churning,
Suitability,
AML,
Discretionary
Account
Review
Supervisory Procedures
Internal
Audit
Parking
License, CRD
pre-search,
CE,
Investment
Advisory
Activities
Review
Back Office Procedures
Firm Business Activities and Compliance Requirement
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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Marketing,
E-Mail,
Advertising,
Correspondence
4.
REVIEW OF ACCOUNTS
Customers’ Accounts
All client accounts shall be reviewed by the Registered Representatives once a year. You as the RR
should update the financial status of your clients and be sure that the investment objectives have not
changed. You may submit the properly signed forms to the Home Office if there are any changes.
Particular attention will be paid to the suitability of investments and adherence to FINRA rules and
Quest Capital's policies. The Compliance Department reserves the right to contact any customers
without informing the representative, should it deem necessary. The Compliance Department may also
request from the Registered Representative on a periodic basis profit and loss statements for any or all
active accounts.
A monthly activity letter will be sent out to each client who has transactions in that month to ensure
their satisfaction. Quest Capital will also send an annual disclosure letter to your client directly to verify
their financial status, investment objective, contact information changes if any.
Employee and Representatives’ Outside Investment Accounts
A person associated with a member, prior to opening an account or placing
an initial order for the purchase or sale of securities with another member, shall notify both the
employer member (Quest) and the executing member (Outside Broker-Dealer), in writing, of his or her
association with the other member; provided, however, that if the account was established prior to the
association of the person with the employer member, the associated person shall notify both members in
writing promptly after becoming so associated.
The Compliance Department of Quest Capital is required to review the duplicate statements and
confirmations of all employees’ and representatives’ investment accounts to prevent potential trading
abuses such as: front running, money laundering and improper funding in your personal investment
accounts and other securities violations. Therefore, all outside investment accounts held by Quest
Employees, Representative or an immediate family member (spouse, child, for example) must be
disclosed and approved by the Compliance Department to be in compliance with regulatory and firm
rules. Failure to do so may result in termination of employment for cause from Quest Capital.
Firm Procedures –
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A form of “Outside Investment Disclosure” must be used and can be downloaded at
www.questcapital.com, under Compliance Department, in the section of “Compliance Forms”.
Please fill out the form and fax over to (949) 457-1005 or mail to home office, attention to the
Compliance Department.
It is the representatives’ responsibility to request that duplicated account statement and
confirmations be sent to the Compliance Department for review. Quest Capital as a courtesy may
send a written request to other broker-dealers for duplicated account statements or confirmations.
A $25 per account annual fee will be charged for compliance review. The $25 charge is waived if
the account is held with Quest Capital. Please mail in the form with your total annual fee.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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5.
All accounts held with Quest Capital will have all transactions reviewed daily by the Compliance
Department via the trade blotter.
REVIEW OF TRANSACTIONS
All transactions for the purchase or sale of securities shall be reviewed by the Registered
Representative, his/her branch manager and the Compliance Department. In the case of the purchase of
a mutual fund, variable insurance products or other “packaged products”, the Compliance Officer or
Supervisor (or Branch Manager) shall indicate such review by initialing a copy of the fund order or
application or account statement. In the case of an order to purchase or sell stocks or bonds, such
review shall be indicated by initialing the order ticket.
In addition, the Compliance Officer or Supervisor (or Branch Manager) shall periodically review all
transactions that have been executed during that period. In reviewing these transactions, particular
attention shall be paid to :
6.
a.
Suitability
b.
“Churning”
c.
Mutual Fund “Switching”
d.
Adherence of firm policies
e.
Unauthorized trading
CUSTOMER COMPLAINTS
All customer complaints, whether oral or written, which are received by a Registered Representative
must be immediately referred to the Compliance Officer. Thereafter, the Registered Representative
receiving the complaint shall document the complaint in memorandum form and send it to the
Compliance Officer within 24 hours. A copy must be kept in the Branch Complaint File, including
copies of all supporting documents.
To help assure that customer complaints are handled expeditiously, all mail addressed to Registered
Representatives received in the home office shall be opened prior to distribution.
All responses or any action taken in response to a customer complaint should be noted in the customer
complaint file, attached to the original complaint, and a copy forwarded to the Compliance Officer.
Please review Chapter 6 – Dealing with the Public, Customer Complaints.
7.
REVIEW OF CORRESPONDENCE
Quest Capital shall review all correspondence pertaining to the solicitation or execution of securities
transactions during its inspection.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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a. OSJ Branches: A copy of correspondence must be initialed by the Branch Office Manager
(BOM) and retained in the branch General Correspondence file for six (6) years. All correspondence
must be approved by the Compliance Officer in writing before being mailed to clients.
b. Non-OSJ: Each non-OSJ branch office must send photocopies of all correspondence
pertaining to securities matters to the home office or OSJ office responsible for supervision of that
office for review and approval. The correspondence must be initialed by the non-OSJ branch manager
before submitting. Copies must be kept on file in the supervising OSJ office and non-OSJ office.
c. Home Office:
Registered Representatives and non-OSJ branches assigned to the
home office are required to obtain advance clearance of letters sent to members of the public. The
Compliance Officer or a designee shall be responsible for the review of all correspondence.
8. REVIEW REGISTRATION FILE OF REGISTERED
REPRESENTATIVE
Designated Compliance Officer must review all information contained in a Registered Representative’s
file. It is the Compliance Officer’s responsibility and duty to ascertain by investigation the good
character, business repute, qualifications and experience of any person prior to accepting his/her
application.
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Form U4: All questions must be answered by the Representative with original signature.
Special review is needed when there is “yes” answer to any of the Disclosure Questions. All
necessary supporting documents are required in order to complete the review.
Form U5: A copy of Form U5 and amendments filed by most recent previous FINRA member
employer is required. Review the Form U5 and all its amendments no later than 60 days
following the filing of the application for registration. It is necessary to obtain a copy of U5
form filed by all previous employers when it is possible. Additional information may be
required from the Registered Representative to support questionable items.
Credit Report: Request necessary documents to support the questionable credit items.
Background Compliance Questionnaire: Representative must answer all questions with
signature and date. Contact Representative for any questionable items and request additional
information or documents when needed.
Independent Contractor Agreements: FINRA Conduct Rule 2263 requires disclosure to
associated persons when signing Form U-4. The Form U-4 contains a predispute arbitration
clause and detailed information within this agreement. Ensure there is no alternation to the
agreement and original signature from Representative is a must.
Background Investigation Form:
Representative must provide employment and history for the past ten years. Leave no gaps
greater than three months between each employment period. Compliance Officer must
supervise the personnel at licensing department to communicate with all of the Representatives
previous employers for the past three years and document the names of the persons contacted
and the date of contact. All past securities employers contact information are required on Quest
Capital-Background Investigation form. It is necessary to communicate with all past securities
employers when it is possible.
Information from CRD web site: Ensure personnel at licensing department do pre-hire search
from the CRD web site and print all related information for Compliance Officer’s review.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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Especially review the reason of U5, registration with previous employer, disclosure questions
filed with previous employer.
No Parking License: Representative must understand this rule by signing the acknowledgement
form.
Authorization of Credit /Background Check: It must have signature of Representative before
we process the credit and background check.
Business Card information: To ensure that all information provided by Representative is
proper and contains no misleading information. In the state of California, Insurance License
number must be printed on the business card.
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Fingerprint Card: Ensure that the personnel at licensing department files all Representative
and Employee fingerprint cards on a timely basis. To follow up the fingerprint card report
provided by FBI and CRD. Ensure that all necessary documents are collected from
Representatives when they are needed.
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COMREC system: (Quest Internal System)
In Quest Capital internal system, once FINRA and Quest approve the RR, the “FINRA OK”
status will be placed in COMREC. However, any approved RR with a “yes” answer to the DRP
pages of U-4 would be placed on “Scrutiny” status in COMREC. Once the “Scrutiny” status is
placed, it will require a “Supervisory Pre-approval” on each transaction.
Ensure licensing department personnel updates COMREC system with RR’s registration
information, contacting information, Continuing Education due date, Commission Payout
program and any outstanding items.
9.
INFORMATION MANUALS:
The Supervisory Procedures Manual shall be maintained by each Registered Representative for use and
reference. Registered Representatives shall be informed periodically of changes to the manuals. All
compliance and operations procedures questions should be directed to the home office Compliance
Designee or the Compliance Officer. Personal copies of the FINRA manual and the MSRB manual
may be purchased through the FINRA by calling (301) 590-6578 or a copy can be down loaded from
www.finra.org site.
10. ANNUAL MEETING AND ANNUAL INSPECTION:
FINRA Rules require the participation of each registered representative, either individually or
collectively, no less than annually, in an interview or meeting conducted by persons designated by the
member at which compliance matters relevant to the activities of the representative(s) are discussed.
Such interview or meeting may occur in conjunction with the discussion of other matters and may be
conducted at a central or regional location or at the representative(s) place of business.
The annual compliance meeting will generally be conducted via webinar from the home office.
The compliance meeting may also be conducted in an individual or group face-to-face meeting
or telephone conference at any business locations. The compliance meeting will be conducted
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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as many times as needed throughout the year under the supervision of the Chief Compliance
Officer.
Representative will be required to evidence his/her attendance of compliance meeting, such as the
telephone bill that can demonstrate the length of attendance, or the length of webinar log in.
Representative will have the opportunity to ask compliance questions and receive answers during the
meeting. You can also call or e-mail your compliance questions if the question were raised after you left
the meeting and you will receive answer from the Compliance Department within a reasonable time.
FINRA Rules requires an annual inspection of each office and each OSJ branch office or other location
held out to the public as an office of securities business.
Registered Branch Office: Quest Capital, at a minimum, conducts twice-a-year surprise inspections of
a FINRA Registered Branch Offices. A Branch Office Inspection Questionnaire and yearly Annual OnSite Questionnaire will be used for guidance. The Compliance Inspector may randomly select client
files, transaction blotters, advertising file, correspondence file and other items for their review. If the
branch office has a representative who is under FINRA order for heightened supervision, then a special
heightened supervisory procedure will be designed and implemented based on the approval of FINRA
and the reason for the heightened supervision order. A primary supervisor will be named in the special
heightened supervisory procedure and the change of supervisor may require FINRA pre-approval.
Quest Capital may design a special inspection check list on a case by case basis to meet the special
situation requirement.
Branch Manager is personally responsible and liable for all activities conducted by the representatives
in his/her branch office. When a representative in a branch signed any indemnification agreements with
Quest Capital, the responsibilities and liabilities stated in the indemnification agreements will also be
the responsibilities and liabilities of the Branch Manager.
Non-Registered Office: Quest Capital conducts a scheduled inspection of non-registered offices
annually. Quest Capital reserves the right to conduct surprise audits when deemed necessary.
You can download the Annual On-Site Inspection Form from www.questcapital.com, in the
Compliance Department, to help you to prepare for the annual audit.
It doesn’t matter if you work in a Registered Branch Office or you work at a non-registered office; you
are required to cooperate with the inspection when the inspection schedule is announced for your area.
Failure to meet with a Quest Capital appointed inspector may subject to a Quest Capital and/or FINRA
disciplinary action or termination.
Registered Representatives are expected to rearrange their schedules in order to attend the annual
meeting or annual inspection. No exceptions will be allowed except if an alternative arrangement is
made with the Compliance Office at home office or for mitigating circumstances. It will be the
responsibility of the Registered Representative to make alternative arrangements for completion of the
annual meeting and annual inspection requirement. Currently, the alternative is to attend a face-to-face
meeting at the home office with a compliance officer or a designee in your local area.
Under Quest Capital’s central control for compliance review, all decisions on subjects related to
securities business, especially on securities transactions. Therefore, issues related to churning,
suitability, investment product and Mutual Fund/Variable Annuity switches are reviewed at the home
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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office by the Compliance Officer. Our On-Site inspector focuses on issues dealing with outside
business activities, advertising, correspondence, e-mail communication with the public,
professionalism, reputation, selling away, receiving client’s funds or securities, customer complaints,
websites, sales promotion, cold calling and scripts. Majority of items require the pre-approval of the
Compliance Department before using and implementing.
11. REGISTERED REPRESENTATIVE ANNUAL COMPLIANCE
QUESTIONNAIRE
A. Registered Representative Responsibility:
The Annual Compliance Questionnaire contains many questions related to Basic Compliance,
Communication with the Public, Outside Activities, Continuing Education survey, Customer Protection,
Paper work and Contact Information update.
Every Representative and Registered Principal who is affiliated with Quest Capital is required to
complete and sign the Annual Compliance Questionnaire annually. Quest Capital will notify you within
what time frame this questionnaire needs to be completed. Timely completion of the questionnaire is
expected, without exception, of all Representatives and Registered Principals.
B. Compliance Officer Review:
The Compliance officer or designee is responsible for the review of each questionnaire received from
the Compliance Inspector or representative. The Compliance Officer should contact RR for any
questionable answers or comments on RR’s questionnaire. Ensure that all questionable items are
cleared and completed if there are any corrections that need to be made from RR side. The needs of
analysis for the Firm’s Continuing Education will be produced annually after reviewing the
questionnaires.
Failure to comply will be deemed a violation of Quest Capital’s policies and procedures.
Disciplinary action may be taken if you do not comply with this procedure. Failure to complete
this requirement may result in sanctions, fines or termination.
12. Outsourcing Arrangements
By providing a clearing outsourcing activities, RBC CS (RBC) is required to have proper
registration ad qualification. Quest Capital executed a clearing agreement pursuant to FINRA Rules
with RBC. All services provided by RBC are contemplated by FINRA rule, MSRB rules, or
applicable federal/state securities laws or regulations. This type of contract will be reviewed by the
President.
RBC has the necessary resources and skills as well as financial capacity to handle all clearing
services for Quest Capital. RBC adopts the same securities rules as Quest Capital to design their
own contingency planning and privacy policy to prepare for disruptions in services and ensure
safeguard all Quest Capital customer’s data and privacy.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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Quest Capital has direct control on its daily compliance activities. Quest may hire an independent
compliance consultant and Certified Public Accountant to conduct an annual audit on its internal
supervisory control procedure, financial book and record accuracy and maintenance procedure.
Quest Capital will file notification to the proper regulator based on business practice needs or
changes in its outsourcing arrangements. Quest Capital will assign access authority to proper
regulators in order to access all information stored with outsourcing providers for any inspection.
All outsourcing arrangements other than the clearing agreement will initially have the contract
reviewed and approved by the compliance department. If any arrangements are changed, the
compliance department will notify the President immediately. The compliance department with the
help of IT staff, views the daily storage reports to ensure all electronic storages are backed up
properly and to ensure all concerns can be corrected in a reasonable time.
13. Testing Regulation SP System
Our Principal and Personnel Responsibilities List is part of our Written Supervisory Procedure
Manual that identifies the Chief Compliance Officer(s) who is responsible for complying FINRA
Rule 3130-Annual Certification of Compliance and Supervisory Program.
Quest Capital hires third party compliance consulting firm to test the effectiveness of such policies
and procedures yearly to ensure continuing compliance with FINRA rules, MSRB rules and federal
securities laws and regulations. The CEO consults with the CCO, other officers as applicable and
other employees, outside consultants, lawyers and accountants to the extent deemed appropriate, in
order to attest to the statements made in the annual certification.
More procedures related to Security and Testing are addressed in either the Back Office Manual or
Supervisory Control Manual. Such as building access, office access and server room access.
Customer Information will be protected in many ways. We may share the customer information
with our clearing firm and product firms for the purpose of completing securities transactions on
behalf of clients. All agreements with clearing firms and other product and service providers
include the third party’s privacy policies.
Privacy Policy
We published our Privacy Policy on line at www.questcapital.com, we also notify the clients in our
Annual Client Letter. If a client who opts out of releasing information, the account will be coded to
block the release of non-public financial information to non-affiliated third parties unless a written
authorization signed by customer(s) is received.
If customer information is requested from outside parties such as regulators, the IRS, and other
government or civil agencies, the request will be referred to the Compliance Department for review
and response.
Computerized customer information is accessed by password protection or other established
controls within the firm (or the clearing firm’s) system to ensure only authorized persons gain
access. For example, registered representatives may access information regarding accounts assigned
to them but not to accounts assigned to others.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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Firm Web Site- the firm’s web site is protected by firewalls, a secure server and anti-virus
programs. It also requires many layers of access password. The integrity of the firm’s internal
computer systems, including privacy protection is subject to regular review.
If required by state law or regulatory rules, the states and regulators will be notified if customer
information is stolen making it subject to potential identity theft.
The Chief Compliance Officer is in charge the supervision for the security of customer information.
Procedure of Disposal of Customer Information and Records – Customer information and
records will be disposed in a manner to prevent unauthorized access or use.
There will be secured removal of trash involving customer information. Paper information will be
burned, pulverized or shredded, so that it cannot be practically read or reconstructed. Electronic
information will be destroyed or erased so that the information cannot be practically read or
reconstructed.
Quest Capital has engaged a third party to provide disposal services and will notify the third party
when customer information is being provided for disposal in accordance with acceptable disposal
procedures.
The Chief Compliance Officer is in charge the supervision for the security of disposal of customer
information and records. Senior Management is also responsible of hiring the third party service
provider.
The testing procedure is included in our Compliance Department Back Office Manual.
²
FINRA Complaints, Investigations and Sanctions:
(c) Requirement to Comply
No member or person shall fail to provide information or testimony or to permit an inspection and
copying of books, records, or accounts pursuant to this Rule.
FINRA Complaints, Investigations and Sanctions:
(b) Notice to Person Associated with Member
If a person associated with a member fails to provide any information, report, material, data, or
testimony requested pursuant to the FINRA By-Laws or the Rules of the Association, the Department
of Enforcement or the Department of Market Regulation may provide written notice to such person
specifying the nature of the failure and stating that the failure to take such action within 20 days after
service of the notice constitutes grounds for suspending the association of the person with the member.
²
FINRA Complaints, Investigations and Sanctions:
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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Effect of a Suspension, Revocation, Cancellation, or Bar
If the Association or the Commission issues an order that imposes a suspension, revocation, or
cancellation of the registration of a person associated with a member or bars a person from further
association with any member, a member shall not allow such person to remain associated with it in any
capacity, including a clerical or ministerial capacity. If the Association or the Commission suspends a
person associated with a member, the member also shall not pay or credit any salary, or any
commission, profit, or other remuneration that results directly or indirectly from any securities
transaction, that the person associated with a member might have earned during the period of
suspension.
Release of Disciplinary Information
(a) In response to a written inquiry, electronic inquiry, or telephonic inquiry via a toll-free telephone
listing, the Association shall release certain information contained in the Central Registration
Depository (CRD) regarding a current or former member, an associated person, or a person who
was associated with a member within the preceding two years, through the Public Disclosure
Program.
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(e) “Complaint” Defined
A “complaint” shall be deemed to mean any written statement of a customer or any person acting on
behalf of a customer alleging a grievance involving the activities of those persons under the control of
the member in connection with the solicitation or execution of any transaction or the disposition of
securities or funds of that customer.
Failure to notify the Compliance Department about any customer complaints may result in fines,
sanctions, or even termination for cause as a registered representative with Quest Capital.
Based on FINRA Rules regarding Reporting Requirements, Quest Capital may file a report to the
FINRA for the customer complaints received by the Compliance Officer. Quest Capital may also file
report to the FINRA for any indictment, information or other criminal complaint, any plea agreement,
or any private civil complaint or arbitration claim against a person associated with a member that is
reportable under question 14 on Form U-4, irrespective of any dollar thresholds Form U-4 imposes for
notification, unless, in the case of an arbitration claim, the claim has been filed in the FINRA Dispute
Resolution forum.
Each person associated with a member shall promptly report to the member the existence of any of the
conditions set forth in paragraph 3070(a) of this Rule. (Please go to www.finra.org and locate the
FINRA manual to get more detailed information on the FINRA regarding Reporting Requirements).
Each member shall report to the Association not later than 10 business days after the member knows or
should have known of the existence of any of the conditions set forth in paragraph (a) of this rule.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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Quest Capital Policy Explanation
Financial Industry Regulatory Authority (“FINRA”) imposes certain Rules on its members, their
employees and sales representatives.
Since you will be operating under the auspices of Quest Capital, it is only natural that you shall be
operating under the same Rules imposed on Quest Capital. Therefore, you agree to abide by all the
Rules as though these Rules were imposed on you in addition to Quest Capital as a member of FINRA.
As a member of the FINRA, we take FINRA’s regulations and Rules very seriously. In most situations
when interpreting the Rules, please substitute your name in place of “member” or “associated person.”
In cases where substitutions are not possible, please seek an explanation from our Compliance
department in writing.
You accept that you are required to maintain close (and sometimes the only direct) relationships with
your clients and shall be solely responsible for your clients' activities. Quest Capital shall act as
supplier of products for sale and shall have no responsibility for any losses as a result of Clients
activities.
We have adopted the above FINRA Conduct Rules as our policy. Please study and understand these
Rules. You can contact our Compliance Officer with any questions. In the rare event that you know of
a violation, you are required to report to us in writing immediately.
Member FINRA, SIPC
23832 Rockfield Blvd., Suite# 130, Lake Forest, CA 92630
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