Collection of Investor Information
The Firm may collect personal information about customers from the following sources:
- 1.Customer questionnaires and other information provided by the customer in writing, in person, by telephone, electronically or by any other means. This information may include name, address, employment information, and financial and investment qualifications, as applicable;
- 2.Information about customers from financial institutions and service providers with whom a customer may have authorized to provide such information to the Firm;
- 3.Transactions in a customer’s account, including account balances, investments, contributions and withdrawals; and
- 4.Verification services and consumer reporting agencies, including a customer’s creditworthiness or credit history, as applicable.
Disclosure of Nonpublic Personal Information
The Firm does not disclose nonpublic personal information about customers or potential customers to affiliates or nonaffiliated third parties except as permitted by law. For example, the Firm may share nonpublic personal information about investors, without the investor’s consent, with affiliated and nonaffiliated parties in the following situations, among others:
- 1.In connection with the administration and operations of the Firm and other of the Firm’s products and services, with the Firm’s brokers, attorneys, accountants, auditors, administrators or other service providers;
- 2.To respond to a subpoena or court order, judicial process or regulatory inquiry;
- 3.In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
- 4.To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
- 5.To respond to requests for information regarding compliance with anti-money laundering laws;
- 6.Upon consent of a customer to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor; and
- 7.To assist the Firm in offering affiliated products and services to investors.
As indicated above, the foregoing may include responses to inquiries for purposes of compliance with anti-money laundering and anti-terrorist due diligence, disclosure or reporting requirements. The Firm also may share nonpublic personal information about customers at customer direction or with customer consent.
Former and Prospective Investors
Protection of Subscriber Information
The Firm maintains physical, electronic and procedural safeguards that comply with federal standards to protect investor information. The Firm restricts access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities.