This Privacy Policy explains the manner in which Coe Hill Advisors, LLC (the "Adviser") collects, utilizes and maintains nonpublic personal information about its clients as required under recently enacted Federal law. All information given to the Adviser and all recommendations and advice furnished by the Adviser to clients shall be kept confidential and will not be disclosed to anyone, except as the Adviser may agree in writing or as may be required to do so by law.
Select any of the following links to be directed to specific portions of the Privacy Policy or related notices.
Collection of Client Information Disclosure of Nonpublic Personal Information Former Clients
Protection of Client Information Additional Privacy Information AML Program & Compliance with USA Patriot Act
Collection of Client Information
The Adviser will collect nonpublic personal information about its clients as part of its engagement with those clients. The Adviser collects this personal information about its clients from the following sources:
- Account forms, subscription forms, client profiles or questionnaires and other information provided by the client in writing, in person, by telephone, electronically or by any other means. This information includes name, address, employment information, and financial and investment qualifications;
- Transactional activity in clients' investment and/or trading accounts, including account balances, investments, contributions/additions, withdrawals/redemptions and fees/commissions;
- Other interactions with the Adviser (for example, discussions with our staff); and,
- Verification services and consumer reporting agencies including a client’s creditworthiness or credit history.
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Disclosure of Nonpublic Personal Information
The Adviser may share nonpublic personal information about its clients or potential/prospective clients with affiliates, as permitted by law. The Adviser does not disclose nonpublic personal information about its clients or potential/prospective clients to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to the client or the client’s account). The Adviser will not share nonpublic personal information about a client with other clients.
The Adviser may share nonpublic personal information, without the client’s consent, with affiliated and nonaffiliated parties in the following situations, among others:
- To respond to a subpoena or court order, judicial process or regulatory inquiry;
- In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
- To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
- To service providers of the Adviser in connection with the administration and operations of the Adviser and its products and services, which may include brokers, attorneys, accountants, auditors, administrators or other professionals;
- To assist the Adviser in offering Adviser-affiliated products and services to its clients;
- To assist the Adviser in providing the highest level of service to its clients; and
- To process or complete transactions requested by a client.
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Former Customers and Investors
The same Privacy Policy applies to former clients of the Adviser.
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Protection of Investor Information
The Adviser maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. The Adviser restricts access to the personal and account information of clients to those employees who need to know that information in the course of their job responsibilities.
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Further Information
The Adviser reserves the right to change this Privacy Policy at any time. The examples contained within this Policy are illustrations and are not intended to be exclusive. This Policy complies with recently enacted Federal law regarding privacy. Clients may have additional rights under other foreign or domestic laws.
Should the client prefer, The Adviser will not disclose confidential personal information to non-affiliated third parties. The client may opt out of those disclosures; that is, the client may direct the Adviser not to make those disclosures (other than those disclosures required or permitted by law). Should the client wish to opt out of disclosures to nonaffiliated third parties, he/she may call the following number: +1 (603) 724-6721 or e-mail info@coehilladvisors.com.
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Adviser Anti-Money Laundering Program & Complaince with USA Patriot Act
“Money laundering” is a scheme designed to conceal or disguise the source of money obtained illegally. Congress enacted the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (“USA PATRIOT Act”) on October 26, 2001 in response to the terrorist events that occurred on September 11, 2001.
The USA PATRIOT ACT created new anti-money laundering (AML) requirements for financial institutions, including, for the first time, hedge funds and investment companies. Financial institutions that fail to comply with these requirements face exposure to severe civil and criminal penalties.
While Investment advisers do not meet the definition of a “financial institution”, an investment adviser that has private investment company and mutual fund clients, however, must implement or arrange for the implementation of anti-money laundering procedures for the investment company clients. Banks and broker-dealers registered as investment advisers are required to comply with anti-money laundering laws. Moreover, an investment adviser that is “willfully blind” to money laundering that is occurring within accounts that it manages may be subject to criminal liability. See 18 U.S.C. §§ 1956 and 1957.
Coe Hill Advisors, LLC (the “Adviser”) is a registered investment adviser and commodity trading advisor firm. It is not a “financial institution”, and does not currently have private investment company or mutual fund clients.
Nonetheless, to the extent applicable given the firm’s type, scope of client base, nature of business, and available compliance resources, Coe Hill Advisors, LLC fully complies with provisions found within the USA Patriot Act as they relate to Anti-Money Laundering (AML). The AML protocol includes provisions for identification of, monitoring and reporting instances where potential suspicious activity or money laundering is suspected.
USA PATRIOT Act Requirements
§ 352 of the USA PATRIOT Act requires a financial institution (as defined in § 31 U.S.C. Section 5318(j)(1)) to implement an anti-money laundering program that has, at a minimum, the following four requirements:
1. Policies, procedures and controls designed to detect and prevent money laundering;
2. A compliance officer whose role is to oversee the program;
3. Training for employees on how to detect and prevent money laundering; and
4. Periodic audits of the anti-money laundering program.
If you have any questions about these policies, please contact the Adviser’s Chief Compliance Officer, Kevin Laffey at: info@coehilladvisors.com or at +1 (603) 724-6721.
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