Privacy of Consumer Information
Chaney Capital Management, as an Investment Adviser, is covered under the definition of a “financial institution” under the Federal Gramm-Leach-Bliley Act. The Adviser is subject to the rules of privacy imposed under the Act and the SEC’s Regulation S-P (the “Privacy Rule”). To maintain compliance with the Act and Regulation S-P every broker, dealer, investment company and registered investment Adviser is required to adopt policies and procedures reasonably designed to safeguard customer records and information. Chaney Capital Management maintains compliance under the Act and State privacy rules.
The types of information the Adviser 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, social security number, employment, assets, income and debt;
- Information about the client’s transactions, accounts, trading activity and parties to transactions, beneficiary information, and health information (if informed);
- Information from other outside sources;
- Any other information that is deemed to be nonpublic personal information as defined by the Act and the state privacy rules.
The staff of CCM realizes that providing personal information is an act of trust and takes the issue of protecting privacy very seriously. Chaney Capital Management values its clients’ trust and confidence. The Adviser does not sell nonpublic personal information we obtain from consumers or clients. All information provided by consumers to Chaney Capital Management, (its Associated Persons), and information and advice furnished by the Adviser to clients, shall be treated as confidential and shall not be disclosed to unaffiliated third parties, except as permitted by clients with written authorization, by application to facilitate the investment advisory services offered by the Adviser via an unaffiliated financial services provider, or as required by law or the rules and regulations of a regulatory body to which the firm and its staff are subject. Former clients are provided the same security as current Clients. Client records are maintained for the time period required by the SEC.
CCM maintains clients records in a controlled environment and records are only available to authorized persons of the Adviser who have a need to access client information in order to delivery advisory services or respond to client requests. Chaney Capital Management’s records are secured during non-business hours.
Clients are welcome to discuss any questions or concerns regarding our privacy policies and procedures directly with the Adviser’s President and Chief Compliance Officer, Stephen J. Chaney.