We respect the privacy of all Clients and prospective Clients (collectively termed “clients” in this section only), both past and present. It is recognized that you have entrusted our firm with non-public personal information and it is important that both access persons and clients are aware of firm policy concerning what may be done with that information.
The firm collects personal information about clients from the following sources:
- Information clients provide to complete their financial plan or investment recommendation;
- Information clients provide in engagement agreements and other documents completed in connection with the opening and maintenance of an account;
- Information clients provide verbally; and
- Information received from service providers, such as custodians, about clients’ transactions.
The firm does not disclose nonpublic personal information about our clients to anyone, except in the following circumstances:
- When required to provide services our clients have requested;
- When our clients have specifically authorized us to do so;
- When required during the course of a firm assessment (i.e., independent audit); or
- When permitted, or required by law (i.e., periodic regulatory examination).
Within the firm, access to client information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices are confidential and they are instructed not to discuss client information with someone else that may request information about an account unless they are specifically authorized in writing by the client to do so. This includes providing information about a spouse’s IRA or a parent’s account.