Privacy requirements

Under the Gramm-Leach-Bliley Act of 1999, all investment advisers must safeguard the privacy of the personal information of their customers and clients. State regulated investment advisers must comply with regulations adopted by the Federal Trade Commission (FTC). For a "plain English" description of the FTC requirements, see the privacy guidance document (.pdf version). Federal covered investment advisers must comply with Regulation S-P adopted by the Securities and Exchange Commission. These regulations cover such things as notices to your clients about the types of personal information collected from or about them and how that information is used, what persons have access to that information, and security procedures put in place to prevent information from being used improperly.