Privacy Policy: We are hearing more and more about threats to privacy and disclosure of information for marketing purposes. What is your policy? My policy is very simple: I will not disclose any information I get from you, including the fact that you are a client of mine, without your permission except as required by law to regulatory or law enforcement agencies.
The SEC has recently adopted requirements concerning disclosure of client information for those investment advisors it regulates. The SEC does not regulate me due to my amount of assets under management. Instead, Virginia regulates me, and they have not yet adopted the SEC's rules in this matter. However, the SEC requirements are a good consumer protection measure, so I will comply with them whether required to or not. In particular, the SEC requires annual disclosure to clients of the advisor's formal privacy policy.
So here goes:
Mark Pankin as an investment advisor collects nonpublic personal information about clients from applications, other forms, and information about your transactions and status of your account(s) with others or me.
I do not disclose any nonpublic personal information about you to anyone except as required by law. Access to your personal and account information is restricted to those who need to know that information in order to provide products or services to you. (That means that my backup person, Ken Hawkins, has access to information about your accounts so that he can place orders. He also has your contact information in case an emergency arises, but he does not have the data you provided to me on your confidential financial profile.)
Your nonpublic information is protected by physical (restricted access, shredding of discarded documents) and electronic (password protection of sensitive files and online access to order placement or account records) safeguards.
If you decide to close your account(s) or terminate my management services, I will adhere to the same privacy policies and practices described above.
That's it. As always, please get in touch with me if you have any concerns or questions or would like additional information.