A Commodity Trading Advisor (CTA)
The confidentiality of client information is of the utmost importance to the Advisor.
The Advisor collects nonpublic personal information about its clients from information provided by the clients on account applications and forms and through transactions that occur in the clients’ trading accounts.
The Advisor does not disclose any nonpublic personal information about its clients to anyone, except as permitted or required by law. At times, the Advisor may be required to furnish complete client records to regulators, legal counsel, courts of competent jurisdiction, or other entities as required by law. In addition, the Advisor may be required to furnish tax information to the Internal Revenue Service.
The Advisor enters into agreements with external compliance/accounting firms to compile performance data for the Advisor’s Trading Program. The performance calculations are required to be compiled in accordance with CFTC Regulations and NFA Rules. The Advisor would provide clients’ records (e.g., month end commodity statements generated by the FCM) to the external compliance firm for purposes of compiling the performance data. The Advisor has obtained reasonable assurance that the external compliance firm will not share the clients’ information with third parties.
The Advisor will not sell clients’ personal information to anyone and no client will be permitted to review other clients’ records.
The Advisor maintains physical, electronic, and procedural safeguards to protect clients’ nonpublic personal information.
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