Our Privacy Policy

The interests of our clients are always given top priority. As part of our firm's long tradition of trust, the confidentiality of client information has been and will continue to be paramount. We maintain high standards to safeguard your personal financial information at all times, and we will remain vigilant in protecting that information. We collect personal financial information to operate prudently and to meet legal and regulatory requirements.

We never rent or sell your name or other personal financial information. We will only share certain information with companies not in our corporate family ("nonaffiliated third parties") as permitted by law for the purpose of servicing your financial needs. The recipients of that information are required to protect the confidentiality and security of that information and may not reuse it for any other purpose.

Questions and Answers about Our Privacy Practices

How does the Privacy Policy protect the confidentiality and security of personal information?

Firstly, people. We restrict access to your personal financial information to personnel who need that information to provide you with our products and services. Our employee communications also reinforce our privacy policies.

Secondly, policies and procedures. We maintain and monitor our physical, electronic, and procedural safeguards, updating them as needed so that we may guard your personal information.

Thirdly, security. We use leading security and encryption methods to help us identify and prevent data breaches and any possible unauthorized disclosure of your personal financial information.

What information do we collect from and about clients?

We must obtain certain information to meet legal and regulatory requirements; exactly what depends on the nature of the client's relationship with us. In all cases, we collect only personal financial information that is either required or necessary to provide personalized financial services to the client. We may obtain information about each client -- name, address, Social Security number, telephone number, income, etc. -- from our order forms and applications. We may collect information about clients' financial transactions -- securities bought and sold, checking transactions, fund transfers, etc. -- through companies in our corporate family ("affiliates"). We may also obtain information about clients from third parties, such as a consumer report from a consumer reporting agency, and we may verify income, identity, or asset information.

What information do we disclose about clients to affiliates?

We may disclose some or all of a client's personal information to our corporate affiliates, including transfer agents, banks, insurance companies and agencies, trust companies, mortgage bankers, securities broker dealers, and investment advisers. We do this in order to offer each client a broad range of products and services and to comply with applicable regulations.

What information do we disclose about clients to nonaffiliated third parties?

We will, as necessary, use various services from nonaffiliated third parties. We use these external service providers for the purpose of supporting the financial products and services we provide to you. For example, we provide information to external service providers so that the client's investment account statements can be properly printed and mailed. These parties must agree to comply with stringent security and privacy policies and procedures. We may also disclose information to government agencies and regulatory organizations when permitted or required by law.

What information do we disclose about former clients and to whom?

We may disclose some or all of a former client's personal information to government agencies and self-regulatory organizations when permitted or required by law, such as when required to file abandoned property reports and to comply with subpoenas and other official governmental requests. If a former client had a loan with us, we may report the performance of that loan to consumer reporting agencies.