It is a goal of LMA to provide clients with a high level of service no matter what disruption the firm may be experiencing. LMA has developed a BCP to respond to events that may create a significant business disruption (“SBD”). Since the timing and impact of a SBD are unpredictable, we will have to be flexible in responding to events as they occur. We plan to quickly recover and resume business operations after a SBD and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and enable our clients to transact business as best we can. In short, our BCP is designed to enable our firm and employees to resume operations as quickly as possible, given the scope and severity of the disruption. However, your orders and requests for funds and securities could be delayed during the SBD. Our BCP addresses the following: records retrieval; data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with clients, employees, and regulators; alternate physical location of employees; critical suppliers, contractors, bank and custodial impact; regulatory reporting; and providing an alternate means for our clients to access their funds and securities if we are unable to continue our business. We have local and off-site back up of electronic files and off-site storage of historical records. The custodians of accounts also store important electronic records in their own systems. We review and incorporate the BCPs of our custodians into our BCP and will communicate alternate instructions as needed.
LMA recognizes that protecting the privacy and security of the non-public personal information (“NPI”) we obtain about our clients is an important responsibility. All financial companies choose how they share your NPI. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your NPI. Even when you are no longer our client, we will only share your NPI as described in this notice. Please read this notice carefully.
What types of information does LMA collect?
The types of NPI we collect and share depends on the product or service you have with us. This information can include items such as your Social Security number, date of birth, government identification, income, account balances, transaction history, employment, bank account(s), your investment experience and financial transactions. For insurance products, information may include past, present and/or future health related matters or provisions of health care and/or policy information. We collect your NPI in a variety of ways. For example, we obtain your NPI when you open an account, provide your client profile suitability information, tell us about your existing investment accounts or deposit checks, or complete an insurance application. We also collect your NPI from other companies, such as from the custodians of your account assets.
How does LMA share your personal information?
All financial companies need to share clients’ NPI to run their everyday business. We share your NPI for our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal or regulatory investigations, to protect the confidentiality and security of your records, or as permitted by law. We may also share your NPI for our own firm’s marketing purposes; to offer our products and services to you.
Federal law gives you the right to limit only sharing NPI about your credit worthiness for our affiliates’ everyday business purposes; sharing NPI about you with our affiliates to market to you; and sharing NPI with non-affiliates to market to you. We don’t share NPI about your creditworthiness with our affiliates for their everyday business purposes. We don’t share your NPI with our affiliates to market to you. We don’t share your NPI with non-affiliates to market to you. We also don’t share your NPI for joint marketing with other financial companies. State laws and individual companies may give you additional rights to limit sharing. We do not share NPI with our affiliates. However, we share your NPI with a non-affiliate for the purpose of aggregating it and providing summary information based on this data to our parent company, Focus Financial Partners, LLC.
How does LMA protect your personal information?
To protect your NPI from unauthorized access and use, we use security measures that comply with federal law and financial industry standards. These measures include electronic safeguards and physical protection. Our policy about obtaining and disclosing NPI may change from time to time. We will provide you notice of any material change to this policy before we implement the change. If you have questions please call us at 800-842-8834 or email email@example.com.
We continually strive to keep client information accurate, secure and confidential. Our confidentiality and business ethics policies provide that all client information is considered private and privileged. We restrict access to information about our clients to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to maintain the confidentiality of your information. We remain committed to protecting your financial privacy.
Federal laws requires financial institutions to obtain, verify, and record information that identifies individuals and entities who open an account and of those who have the authorization to direct transactions. What does this mean for you? We will ask for your name, address, date of birth and other information that will allow us to properly identify you. We may also ask to visually verify your state or government issued driver’s license, passport, or other valid identifying documents. Accounts may not be titled in contradiction to government issued identification documents. For entity accounts, formation documents to verify ownership, authorized individuals and the signors CIP information is required.
1First Clearing is a trade name used by Wells Fargo Clearing Services, LLC, Member SIPC, a registered broker-dealer and non-bank affiliate of Wells Fargo & Company.