Our clients have trusted us to help them achieve
financial well being. To maintain that trust, we are committed to protecting the privacy and
security of the personal information that we collect about our clients. This notice is
intended to help you understand how we collect, handle, and safeguard that information.
We treat the personal information of our clients in a confidential manner. We do not
provide any information to unrelated companies for the purpose of marketing their products or
services to our clients. When you establish a relationship with us, you are requested to furnish personal and financial
information used to assist in assessing your investment objectives and goals. The information
you share with us is often private and confidential, and we are therefore committed to its protection.
In addition to the information collected, during the course of our relationship we may also collect
a variety of non-public personal information from other sources. The confidential information
we collect may include the following:
JHB Financial Associates does not share client information with any third party other than
those that are authorized by you or that are required in order for us to provide services agreed
upon by the client, service an account, execute a transaction, or if required to do so by regulation
or law. We may share information with our Broker/Dealer, Mutual Service Corporation, its parent company LPL Financial
its clearing correspondent Pershing, a third party money manager or unaffiliated custodian as is
necessary to provide advisory services.
JHB Financial Associates has established policies to maintain physical, electronic, and
procedural safeguards to maintain the confidentiality of the personal information of our clients.
Appropriate measures are taken to ensure that access is available only to those individuals who need
to know that information in order to provide our products and services.
Regulation SP Privacy Act
1. Privacy of Client Financial Information (Regulation S-P) As a result of the recently enacted Regulation S-P, JHB Financial Associates, also referred to
as the adviser, has adopted policies and procedures reasonably designed to (a) ensure the confidentiality
of client records and information; (b) protect against any anticipated threats or hazards to the
security of client records and information; and (c) protect against unauthorized access or use of
client records or information that could result in substantial harm or inconvenience to any consumer.
The privacy provisions of Regulation S-P will apply to information that is non-public personal information.
Definitions according to Regulation SP
Nonpublic information, under Regulation S-P, includes personally identifiable financial information and any list, description, or grouping that is derived from personally identifiable financial information.
Personally identifiable financial information is defined to include three categories of information:
- Information Supplied by Client: Any information that is provided by a client or prospective client to the adviser in order to obtain a financial product or service. This would include information or material given to the adviser when entering into an investment advisory agreement.
- Information Resulting from Transaction: Any information that results from a transaction with the client or any services performed for the client. This category would include information about account balances, securities positions, or financial products purchased or sold through a broker/dealer.
- Information Obtained in Providing Products or Services: Any information obtained by the adviser from a consumer report or other outside source which is used by the adviser to verify information that a client or prospective clients has given on an application for advisory services or insurance products.
As general policy, the adviser will not disclose personal financial information about any client to non-affiliated third parties except as necessary to establish and manage the client's account(s) or as required by law. In these situations, personal financial information about a client may be provided to the broker/dealer or other custodian maintaining these accounts.
In addition, the adviser will restrict access to client's personal financial information to those employees who need to know such information in order to provide products or services to clients. The adviser will maintain physical, electronic, and procedural safeguards that comply with federal standards to guard each client's personal financial information. Such safeguards include restricting the use of any information contained on the Client Investment Questionnaire to each client's personal account manager, the manager's supervisor and the adviser's Compliance Officer or such other persons as the Compliance Officer deems as needing to know the information. Hard copy of client personal financial information will be maintained in the adviser's central files, and will be secured (locked) after normal business hours. Electronic access to client personal financial information will be restricted to the client’s account manager handling the account through the adviser's local area network (LAN). Electronic LAN access will also be available to the manager's supervisor and adviser's Compliance Officer.
3. Delivery of the Adviser's Privacy Notice.
Each client will be provided with a copy of the adviser's Privacy Notice upon opening his/her account. In addition, each active client of the adviser will be provided with a copy of the Privacy Notice annually.
Mutual Service Corporation & LPL Financial are affiliated companies — Members, FINRA/SIPC
JHB Financial Associates is not affiliated with Mutual Service Corporation or LPL Financial
FINRA | SIPC
