Reminder - Annual Privacy Policy Notification Obligation

This is a reminder that all investment advisers (whether or not registered with the SEC or one or more states) have to provide a written Privacy Policy to clients that are natural persons (including IRAs) describing such investment advisers' privacy policies and procedures when the client relationship is established and, thereafter, on an annual basis (i.e., at least once every year), even if there have been no changes to the existing Privacy Policy.

As a practical matter, the Privacy Policy may be combined with other documents so long as it is clearly identified. While not required to be included in a registered investment adviser's Form ADV, some registered investment advisers choose to attach their Privacy Policy to the Form ADV (thereby helping to ensure delivery to each client at the time the relationship is initially established, and on an annual basis thereafter).  

 

Note that an investment manager may also include its Privacy Policy in the Subscription Documents of the investment fund managed by such manager and then separately distribute the Privacy Policy on an annual basis thereafter. 

Cheryl Spratt