SEC Regulation S-P (Privacy of Consumer Financial Information), which was adopted to comply with Section 504 of the Gramm-Leach-Bliley Act, requires investment advisers to disclose to their clients/investors, who are natural persons, its policies and procedures regarding the use and safekeeping of client/investors records and information.
BRAM will not disclose client/investor records and information including non-public personal information and consumer report information (collectively, “client/investor information”) to anyone unless such disclosure is permitted or required by law.
1. BRAM shall not sell client/investor information to anyone.
2. BRAM will restrict access to client/investor information to individuals within BRAM who require the information in the ordinary course of servicing clients/investors accounts. lient/Investor
information is used only for business purposes.
3. BRAM has developed procedures to safeguard client/investor records and information (See Attachment A).
4. Client/investor information may only be given to third-parties under the following circumstances:
• To other firms as directed by clients/investors, such as accountants, lawyers, etc.;
• To specified family members (as authorized by law and/or the client/investor);
• To third-parties as needed to provide requested services; and
• To regulators and others, when required by law.
6. BRAM shall provide a Privacy Notice (See Attachment B) to clients/investors upon inception of the relationship and annually thereafter. The Privacy Notice shall be furnished to clients/investors in a written format and BRAM will maintain a record of the dates when the Privacy Notice is provided to clients/investors. Prior to October 1, 2007, this Privacy Notice was furnished to clients within Form ADV Part II.
9. If an employee receives a complaint regarding a potential identity theft issue (be it from a client/investor or other party), the employee should immediately notify the CCO. The CCO will thoroughly investigate any valid complaint (refer to the client/investor complaint policy), and maintain a log of all complaints as well as the result of any investigations.
10. Extraneous documents containing any client/investor information or sensitive consumer information shall be shredded or destroyed.
Only with written client consent may BRAM employees disclose information about clients to:
1. agent(s) that pay a referral fee (clients must sign a written acknowledgement before any such
referral fee can be paid); or
2. prospective future investors through representative client lists used in marketing presentations.
dissemination of the Privacy Notice