Privacy Policy Notice
Cooper McManus (the advisor) is a registered investment advisor in the business of providing investment advisory services to clients. The advisor is committed to safeguarding the confidential information of its clients. The advisor holds all personal information provided to it in the strictest confidence. The advisor’s Investment Advisor Representatives may also be registered representatives of SAI, a registered broker/dealer that is not affiliated with the advisor. The advisor may also General Information & Disclosure Statement 11/2010 21 have relationships with other nonaffiliated investment advisor firms, such as SAA, an affiliate of SAI, insurance companies, trust companies, custodians and other financial institutions. Except as required or permitted by law, the advisor does not share confidential information about clients with nonaffiliated third parties. In the unlikely event there were to be a change in this fundamental policy that would permit additional disclosures of clients confidential information, the advisor will provide written notice to the client, and the client will be given an opportunity to direct the advisor as to whether such disclosure is permissible.
AN IMPORTANT NOTICE CONCERNING CLIENTS’ PRIVACY
CUSTOMER INFORMATION COLLECTED. The advisor collects and develops personal information about clients, and some of that information is nonpublic personal information (Customer Information). The essential purpose for collecting Customer Information is to provide and service the financial products and services the client obtains from the advisor. The categories of Customer Information collected by the advisor depend upon the scope of the engagement with the advisor and are generally described below. As an investment advisor, the advisor collects and develops Customer Information about the client in order to provide investment advisory services. Customer Information collected includes:
• Information received from the client on financial inventories through consultation with the advisor’s associated persons. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning the client’s financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
• Information developed as part of financial plans, analyses or investment advisory services.
• Information concerning investment advisory account transactions, such as wrap account transactions.
• Information about the client’s financial products and services transactions with the advisor.
DATA SECURITY. The advisor restricts access to Customer Information to associated persons and employees who need the information to perform their job responsibilities within the firm. The advisor maintains agreements, as well as physical, electronic and procedural securities measures that comply with federal regulations to safeguard Customer Information about the client.
USE AND DISCLOSURE OF CUSTOMER INFORMATION TO PROVIDE CUSTOMER SERVICE TO CLIENT ACCOUNTS. To administer, manage and service client accounts, process transactions and provide related services for client accounts, it is necessary for the advisor to provide access to Customer Information within the firm and to nonaffiliated companies such as SAI, SAA, other investment advisors, other broker/dealers, trust companies, custodians and insurance companies. The advisor may also provide Customer Information outside of the firm as permitted by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.
FORMER CLIENTS. If a client closes an account with the advisor, the advisor will continue to operate in accordance with the principles stated in the Notice.
REQUIREMENTS OF FEDERAL LAW. In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, including broker/dealers and investment advisors, to protect the privacy of Customer Information. To the extent a financial institution discloses Customer Information to nonaffiliated third parties, other than as permitted or required by law, clients must be given the opportunity and means to opt out (or prevent) such disclosure. Please note that the advisor does not disclose Customer Information to nonaffiliated third parties, except as permitted or required by law (e. g., disclosures to service client’s account or to respond to subpoenas).