Policies
(Reviewed 5/2017)
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) or any other services provided to you on our behalf.
· 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.