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Privacy Notice
(Reviewed
6/2011)
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).
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.
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.
Firm Brochure ADV
Part 2
Spectrum offers the Firm Brochure ADV Part 2 on the
opening of each client account and material changes as
they apply. To ensure all clients are offered our
updated Firm Brochure ADV Part 2 you can request a copy
by calling our office at 757-463-7600 or download from
our disclosures on our website www.InvestSpectrum.com.
CODE OF ETHICS
OFFERING
Spectrum offers its Code of Ethics on the opening of
each client account. To ensure all clients are
offered our Code of Ethics, you can request a copy by
calling our office at 757-463-7600 or download from our
disclosures on our website www.InvestSpectrum.com.
It is important to contact Spectrum if there are any
changes in your personal/financial situation or
investment objectives for the purpose of
reviewing/evaluating/revising our previous
recommendations and/or services to you. Please also
advise Spectrum if you intend for us to impose, add, or
modify any restrictions to our management services for
your account.
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