Policies
(Reviewed 5/22/09)Proxy |
Privacy
Spectrum
Financial, Inc. honors our client’s right to privacy and
strives to maintain the highest standards of
confidentiality.
In that respect, we are
providing this Privacy Notice to all of our clients in
accordance with Regulation S-P as released by the SEC
(Securities Exchange Commission).
Proxy
Statement
Spectrum does not provide services
for proxy voting to its clients. All proxies are sent
directly to clients from the custodian. Spectrum
periodically reviews client options at each custodian to
ensure proper coding is maintained on all client
accounts. If any client receives material contrary to
Spectrum’s proxy voting statement, they should contact
our office immediately. Spectrum occasionally votes
proxies for its principals. Questions concerning proxy
voting can be directed to our Client Services
Department.
Privacy Policy
Privacy Policy.
Spectrum’s policy is to protect
personal client information.
We
do not sell or maintain lists for any outside
nonaffiliated marketing firms.
We are committed to
maintaining physical, electronic, and procedural
safeguards to protect any personal information we obtain
about our clients.
Information Collected About You.
The non-public personal
information we collect about our clients comes primarily
from the account applications, management agreements,
and client profiles you submit to us when opening a
managed account.
We may also collect
information about your transactions and account history
for your managed accounts through various nonaffiliated
companies such as mutual funds, life insurance
companies, brokerage houses and trust companies.
Use and Disclosure of Information.
Spectrum will not disclose
personal client information, except as permitted by law
under the following circumstances:
·
Your written request to provide information to a third
party.
·
To
establish or maintain an account with a nonaffiliated
third party, such as a clearing broker,
life insurance
company, trust company or mutual fund company in which
Spectrum would actively manage.
·
To
sub-advisers contracted by Spectrum to actively manage
specific strategies.
·
To
render services that you have requested (as in
completing a wire transfer or other withdrawal from your account).
·
To
government entities or other third parties in response
to subpoenas or other legal processes as required by law.
Security Policy.
We maintain
physical, electronic, and procedural security measures
that comply with applicable state and federal
regulations to safeguard confidential client information.
Access to
confidential client information is authorized only for
those Spectrum employees who require information to
perform their job functions.
Closed or Inactive Accounts.
If you decide to close your
account (s) or become an inactive customer, we will
adhere to the privacy policies and practices as
described in this notice.
Changes to this Privacy Notice.
If we make any substantial changes
in the way we use or disseminate confidential
information, we will notify you.
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