Privacy
Family Management Corporation and Family Management Securities, LLC (collectively, “Family Management”) values our customers and respects their right to privacy. We pledge our commitment to treating client information responsibly and we have established the following policy to assure you that we are protecting our customer’s privacy.
We hope you will take a moment to review the privacy policy of the Family Management. We are proud of our policy and practices, and we want you to know how we protect client information and how we use it to service client accounts.
How do we protect the confidentiality and security of client information?
Family Management maintains physical, electronic and procedural safeguards to ensure personal information is treated responsibly and in accordance with our privacy policy. Employees who have access to customer information may use it only for legitimate business purposes. In addition, we safeguard customer information in accordance with applicable data security regulations.
What personal information do we collect about customers?
Family Management collects personal information about clients from the following sources:
• Information we receive from customers on applications and other forms;
• Information about transactions with us through affiliates; and,
• Depending upon the product clients are utilizing, information we receive from consumer reporting agencies, attorneys, accountants, or others.
Family Management may disclose this information to entities that perform marketing (e.g. newsletter fulfillment center) and administrative services on our behalf or as required or permitted by law for legal, regulatory or other purposes.
Family Management has always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust. Within Family Management and among our services providers (e.g. clearing firm), we restrict access to information to those that require that access in order to provide products and services to our clients.
We may share personal information with the following entities:
• Affiliates – Information collected from one affiliate may be shared with other affiliates for investment or advisory purposes. Please also see the Sharing of Information with Affiliates section below;
• Unaffiliated service providers (such as printing\mailing fulfillment services);
• Government agencies and law enforcement officials (for example, for tax reporting or under court order);
• Other organizations, with customer consent (such as credit agencies or banks);
• Other organizations, as permitted by the laws that protect customer privacy (such as for fraud prevention); and,
• We do not sell customer personal information to anyone.
The law allows clients to “opt out” of only certain kinds of information sharing with third parties. We do not share personal information about you with any third parties that triggers this opt-out clause.
If you are a former customer, your information is treated in the same manner as the information of current customers.
Sharing of Information with Affiliates (Regulation S-AM)
Federal law gives clients the right to limit some but not all marketing from Family Management.
Clients may limit Family Management from marketing their products or services to them based on their personal information that they collect and share with each other. This information includes their income, account history, and credit score.
Federal law also requires us to give clients notice to tell them about their choice to limit marketing from Family Management. Family Management assumes clients have chosen to limit marketing offers from Family Management until clients tell us to change that choice.
It is important to understand that there is no requirement for Family Management to give clients notice or the ability to opt-out when an affiliate has a pre-existing business relationship with the client, or provides marketing material in response to an affirmative request by the client, or in response to a communication initiated by the client.
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Business Continuity Planning
Family Management has adopted a business continuity plan that is designed to assure each client timely access to their cash and securities in the event of a significant business disruption.
A significant business disruption may range from a fire or a communications failure that solely affects Family Management to something significantly larger including a regional electrical black-out, flooding or a terrorist attack that may interrupt the operations of either the securities markets or the activities of a crucial number of firms essential to the operations of those markets.
In addition to the fact that Family Management has always maintained continuity plans as a part of our prudent approach to business, FINRA also requires us to invest in contingency planning, back-up facilities and training. Family Management reviews its business continuity plan annually and updates it as necessary. Our plan outlines the actions we will take in the event of a building, citywide or regional incident including relocating personnel to a fully equipped, seamlessly operable and rigorously maintained alternate physical location.
In the event of a significant business disruption that affects Family Management’s main office solely, we anticipate re-commencing operations promptly either the same day or at the start of business the following day. Should Family Management determine that it cannot recommence business in a manner that is most consistent with best serving our clients, we will instruct our clients to contact our clearing firm, Pershing, LLC for instructions to access the cash and securities held in their brokerage accounts.
We will use the best and most appropriate means available to contact our clients in the event of a significant business disruption. Of course, clients can always contact us at our main number where we will promptly leave an instructive message (though promptly will depend based on the scope of the disruption). If we are, or anticipate that we will be promptly, operating from our alternate location, calls will be routed there or clients will be informed as to when we believe that routing will commence. Otherwise, clients will be referred to Pershing for instructions to access the cash and securities held in their brokerage accounts. The telephone numbers for Family Management and Pershing are listed below. Please remember to call us first. This is a crucial part of the intersection between our plan and Pershing’s.
Emergency Phone Numbers
Family Management 212.872.9600
Pershing 201.413.3635
This is a summary of our plan, the full version in maintained by Family Management.
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Cybersecurity
If you believe that any of your online accounts (email, banking, brokerage, etc.) have been compromised or if you have been the victim of cyber theft or “hacking”, please notify your Family Management Securities client service representative immediately.
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Customer Complaints
In accordance with Rule 17a-3, please be advised that any customer complaints may be directed to Family Management Securities, LLC., 485 Madison Ave, 19th Floor, New York, NY, 10022: Attn: Chief Compliance Officer, or clients may contact the Chief Compliance Officer at 212-872-9637.
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Financial Industry Regulatory Authority
REQUIRED ANNUAL FINRA INFORMATION: FINRA MAINTAINS A TOLL-FREE PUBLIC DISCLOSURE HOTLINE WHERE INVESTORS MAY CALL TO REQUEST DISCLOSABLE BACKGROUND INFORMATION ON ANY LICENSED BROKER OR BROKER-DEALER. TO CALL THE HOTLINE, DIAL 1-800-289-9999. FINRA ALSO MAINTAINS AN INTERNET WEBSITE WHERE INVESTORS MAY OBTAIN USEFUL INFORMATION CONCERNING FINRA POLICIES, PROCEDURES AND SERVICES. THE WEB SITE CAN BE ACCESSED AT WWW.FINRA.ORG. ADDITIONALLY, FINRA HAS A BROCHURE WHICH DESCRIBES THE INVESTOR EDUCATION AND PROTECTION PROGRAM. YOU MAY REQUEST THIS BROCHURE EITHER THROUGH THE FINRA WEB SITE OR BY CALLING THE TOLL-FREE PUBLIC DISCLOSURE HOTLINE.
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Securities Investor Protection Corporation
You may obtain information about the Securities Investor Protection Corporation (“SIPC”), including a SIPC brochure, by contacting SIPC by telephone ((203) 371-8300) or by visiting its web-site at (www.sipc.org).
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