January 1, 2020
Commitment to Clients
Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal and State law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.
Collection of Personal Information
The collection and use of confidential and nonpublic personal client information is fundamental to our ability to provide financial planning and investment management services, when applicable, to our clients and investors. We collect certain financial information to determine an investor’s eligibility, suitability and risk-tolerance. In the normal course of managing client relationships and servicing clients’ financial and investment needs, we may collect the following categories of nonpublic personal information:
- Personal identification information
- General and specific occupation and business information
- Business affiliations and special interests
- Financial and investment objectives, experience and risk tolerance
- General and specific personal net worth, income and other financial information
- Bank account information
- Health and Life insurance information
The level of detail obtained within these categories depends upon the nature of the products and services we provide to a particular client. Generally, nonpublic personal information is obtained directly from clients or their representatives through personal meetings, telephone conversations, written communications, questionnaires and supplemental documentation provided in connection with investor subscriptions for interests in private funds, applications, health and medical records provided or completed in connection with underwriting and delivering insurance policies, and other reports, forms or information provided physically or electronically.
We may also receive information about clients from third parties authorized by the client to provide such information, and we may obtain personal information from third parties in order to verify a client’s or investor’s identity.
MCM can share certain operating systems that may contain personal investor information. In some cases, MCM has delegated responsibility for the performance of services to a third-party service provider, and information is shared to the extent necessary to perform the delegated duties.
How We Safeguard and Handle Personal Information
MCM considers the protection of sensitive information to be a foundation of customer trust and a sound business practice.
We maintain procedural safeguards to protect your financial and other personal information, and we continually assess new technology with the aim of adding new safeguards to those we have in place.
Within MCM and among our service providers, we restrict access to personal information to those who require it to provide products and services to you. In the normal course of providing services to our clients or investors, it may be necessary for us to disclose specific client or investor information (i) to companies or organizations which provide certain products or services on our behalf, (ii) to regulatory agencies or (iii) as may be permitted or required by law.
Electronic Access and Communications
As part of our commitment to the security of electronic access and transmission of information, we have implemented various security measures to provide a high level of privacy.
Conclusion and Contact Information
We also make every effort to keep information current and accurate, and if any inaccuracy is identified in connection with client information, we request that the client or his or her representative contact a member of the firm so that our records can be updated.
We recognize that our client and investor relationships are based on trust and that you expect us to act in your best interests. We hold ourselves to the highest standards to maintain and use client confidential and nonpublic personal information responsibly. Client information is used primarily to provide products and services or to make clients aware of products and services that we offer.
Malvern Capital Management, LLC
5 Great Valley Parkway, Suite 312
Malvern PA 19355