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REGULATION BEST INTEREST DISCLOSURE
REGULATION BEST INTEREST DISCLOSURE – SUMMARY
This summary provides information about our relationship with you, our conflicts of interest, costs and fees, and the standard of conduct that applies when we make recommendations. It supplements, and provides additional information on topics discussed in, our Form CRS (which is limited in size by the SEC), as well as the separate disclosures, prospectuses, account forms, and account agreements we provide over the course of our relationship.
Who we are and what we offer
Stratosphere Capital, LLC is registered with the U.S. Securities and Exchange Commission (SEC) as a broker-dealer and is a member of FINRA and SIPC. As a broker-dealer, we transact business primarily in IPO underwritings, follow-on offerings, U.S. equities, fixed income securities, and private placements. We do not offer options. We are not an investment adviser; our registered representatives are stockbrokers, not Registered Investment Advisers (RIAs), and they may not represent themselves as advisers.
Our standard of conduct
When we make a recommendation to a retail client, Regulation Best Interest requires us to act in your best interest at the time the recommendation is made, and not to place our financial interests ahead of yours. Before making a recommendation, we must satisfy four obligations:
- Care — we exercise reasonable diligence, care, and skill, based on your investment profile, risk tolerance, time horizon, and the potential risks, rewards, and costs of the recommendation.
- Conflict of Interest — we maintain written policies and procedures to identify and disclose, mitigate, or eliminate conflicts of interest, including eliminating sales contests, quotas, and bonuses tied to the sale of specific securities.
- Disclosure — we disclose the scope and terms of our services, our fees and costs, and any material conflicts of interest, before or at the time of a recommendation.
- Compliance — we maintain written supervisory procedures reasonably designed to achieve compliance with Regulation Best Interest.
How we are compensated
We and our registered representatives are compensated through underwriting fees and commissions from issuers in connection with IPOs, follow-on offerings, and private placements, and through commissions, markups, and markdowns on secondary-market transactions. We may also receive compensation from issuers or other third parties.
Conflicts of interest
These compensation arrangements create conflicts of interest, because they give us a financial incentive to recommend that you transact, to recommend larger or more frequent transactions, or to recommend products for which we receive greater compensation. We maintain written policies and procedures reasonably designed to identify, disclose, mitigate, or eliminate these conflicts, and we disclose material conflicts of interest to you before or at the time of a recommendation.
Material limitations and monitoring
We offer only certain products and account types, and other products or account types we do not offer may also suit your needs. We do not provide an account monitoring service, and we do not act in a fiduciary capacity as a Registered Investment Adviser.
For the full disclosure — including additional detail on our conflicts of interest, compensation, and account types — please see the Regulation Best Interest Disclosure (PDF) above and our Form CRS.