Column Capital Advisors, LLC, as a Registered Investment Advisory Firm, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and in conjunction with the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P” or the “Privacy Rule”). Column Capital Advisors, LLC is therefore subject to the rules of privacy imposed under the Act and the SEC Rule.
The Privacy Rule requires every broker, dealer, investment company, and registered investment Advisor to adopt policies and procedures reasonably designed to safeguard customer records and information. Column Capital Advisors, LLC maintains compliance with the Privacy Rule and takes the issue of protecting client privacy seriously.
The types of information the Advisor may collect during the normal course of business may include: information provided from applications, forms and other information provided to us either verbally or in writing, and include but are not limited to your name, address, phone number, account information, and social security number, and beneficiaries, health information, employment, assets, income and debt; information about your transactions, accounts, trading activity and parties to transactions; information from other outside sources; and any other information that is deemed to be nonpublic, personal information as defined by the Gramm-Leach-Bliley Act and by the Securities and Exchange Commission’s Privacy Act.
The staff of Column Capital Advisors, LLC realizes that providing personal information is an act of trust. Column Capital Advisors, LLC values its clients’ trust and confidence. The Advisor will never sell or share the nonpublic personal information that we obtain from or in reference to our clients. All information provided by clients to Column Capital Advisors, LLC and our staff, and information and advice furnished to clients by the Advisor, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the Advisor via an unaffiliated financial services provider, or as required by any rule, regulation or law. The SEC routinely audits Registered Investment Advisors to ensure adherence to compliance rules and regulations. Part of the regulator’s routine examination process may include a review of client files for suitability of investments and advice provided. Column Capital Advisors, LLC’s policy to protect client information extends beyond the termination of the Engagement Letter or Client Agreement. Client records are maintained for the time period required by the SEC (five years after the effective date of termination) and are thereafter safely destroyed.
Column Capital Advisors, LLC strives to only recommend financial services providers that share our privacy policies, but clients are encouraged to request each specific firm’s written policy for review.
Column Capital Advisors, LLC maintains client records in a controlled environment and records are only available to authorized persons of the Advisor who have a need to access client information in order to deliver Advisory services or respond to client requests. Clients are encouraged to discuss any questions regarding our privacy policies and procedures directly with Jeffrey J. Yu, Chief Compliance Officer of Column Capital Advisors, LLC.