protecting private information regarding its clients and potential clients as a top priority. Pursuant to the
requirements of the Gramm-Leach-Bliley Act (the “GLBA”) and guidelines established by the
Securities Exchange Commission regarding the Privacy of Consumer Financial Information
(Regulation S-P), the Company has instituted the following policies and procedures in an effort to
ensure that such nonpublic private information is kept private and secure. This policy also outlines how
the Company and its Associated Persons are allowed to use the confidential personal information
collected in connection with its advisory activities.
identifiable information, including information contained in consumer reports, of our current and former
J. Richard Coe is the Chief Compliance Officer (CCO) of the Company. The CCO is responsible for
administering the Company’s policies on safeguarding and protecting the nonpublic personal
information of clients collected by the Company, and to ensure that nonpublic personal information of
the Company’s clients is shared only with Associated Persons and others in a way that is consistent
with the Company’s Privacy Notice and the procedures contained in this Policy.
Associated Persons with questions concerning the collection and sharing of, or access to, nonpublic
personal information of the Company’s clients must look to the Company’s CCO for guidance.
Violations of these policies and procedures will be addressed in a manner consistent with other
Company disciplinary guidelines.
The Company limits the use, collection, and retention of client or potential client information to what we
believe is necessary or useful to conduct our business or to offer quality products, services, and other
opportunities that may be of interest to our clients or potential clients.
The Company collects nonpublic personal identifying information about its clients and/or potential
clients such as name, address, telephone number, social security number or taxpayer ID number, date
of birth, employment status, annual income, and net worth. The information is collected when the client
completes account opening documents, signs our agreement for services, and through the client’s
account custodian or other authorized representatives, e.g. attorney, accountant, bank, etc.
The Company may disclose nonpublic personal information about clients or former clients to certain
nonaffiliated third parties. Unless otherwise notified by the CCO, no Associated Person may share
such information with unaffiliated third parties on behalf of the Company without prior written
client to opt out of the information sharing arrangement.
In certain circumstances, Regulation S-P permits the Company to share nonpublic personal
information about its clients with nonaffiliated third parties without providing an opportunity for those
individuals to opt out. These circumstances include sharing information with a nonaffiliate (1) as
necessary to effect, administer, or enforce a transaction that a client requests or authorizes; (2) in
connection with processing or servicing a financial product or a service a client authorizes; and (3) in
connection with maintaining or servicing a client account with the Company.
From time to time, the Company may have relationships with nonaffiliated third parties (such as
attorneys, auditors, accountants, brokers, custodians, and other consultants), who, in the ordinary
course of providing their services to us, may require access to information containing nonpublic
information. These third-party service providers are necessary for us to provide our investment
advisory services. When we are not comfortable that service providers (e.g., attorneys, auditors, and
other financial institutions) are already bound by duties of confidentiality, we require assurances from
those service providers that they will maintain the confidentiality of nonpublic information they obtain
from or through us. In addition, we select and retain service providers that we believe are capable of
maintaining appropriate safeguards for nonpublic information, and we will require agreements from our
service providers that they will implement and maintain such safeguards.
The Company may also share information when it is necessary to effect, administer, or enforce a
transaction requested or authorized by clients. In this context, “necessary to effect, administer, or
enforce a transaction” includes what is required or is a usual, appropriate, or acceptable method:
The Company may disclose information to nonaffiliated third parties as required or allowed by law. For
example, this may include disclosures in connection with a subpoena or similar legal process, a fraud
investigation, recording of deeds of trust and mortgages in public records, or an audit or examination.
As discussed above, the Company may share nonpublic client information with unaffiliated third
parties. Therefore, the Company will provide the right for its clients to opt out of sharing with
nonaffiliated third parties at the inception of the advisor client relationship, and annually thereafter.
Upon oral or written request from the client, the Company will provide a current privacy notice to client
for the purposes of revising or rescinding opt out directions.
Where two or more individuals jointly obtain a financial product or service from the Company, one
client can opt out for all associated joint clients or each of the associated joint clients can opt out
individually. Not all clients need opt out before implementing opt-out directions for another associated
joint client. If one associated joint client opts out and another does not, information may only be
shared regarding the individual who did not opt out.
The Company may share information with affiliated parties and shall inform clients, in its privacy
notice, of the type of information shared and the category of parties with whom such information is
shared. Client information may be shared for legitimate business purposes only.
The Company has developed a Privacy Notice, as required under Regulation S-P, to be delivered to
clients initially and to current clients on an annual basis. The notice discloses the Company’s
information collection and sharing practices and other required information. The notice will be revised
as necessary any time information practices change.
disclosure to clients, if there is a change in the Company’s collection, sharing, or security practices.
If two or more individuals jointly obtain a financial product or service from the Company, the Company
may satisfy the initial, annual, and revised notice requirements by providing one notice to those