This notice complies with the Gramm‐Leach‐Bliley Act and federal regulations governing privacy of the financial information applicable to our clients. We are committed to providing our clients with quality service. While collecting information about you is essential to meet your needs, we recognize the importance of handling your personal information with care. Accordingly, we have established this Notice of Privacy and related policies.
Confidentiality and Security of Your Information
We maintain appropriate physical, electronic, and procedural safeguards to protect the security and confidentiality of our non‐public personal information. We educate our employees about the terms of this policy and the importance of customer privacy. We restrict access to nonpublic personal information about you to those employees and others who need to know that information to provide services to you, to maintain your accounts, or conduct our business.
Information We Collect About You
Collecting information from you is essential to our ability to offer quality services. As part of that process, we may collect nonpublic information about you from the following sources:
• Information we receive from you on applications and other forms;
• Information about your transactions with us;
• Based upon the services provided, Information we receive from consumer reporting agencies, government agencies, and from your agent banks and prime brokers where applicable; and
• Information that is used to facilitate emails from you.
Categories of Information We Disclose and to Whom
We do not disclose any information about our clients or former clients to anyone, except as permitted or required by law. We may disclose the types of information listed below to companies that help us conduct our business, that perform administrative or other services on our behalf, or to other financial institutions with which we now or may have joint marketing agreements:
• Information we receive from you on applications and other forms, such as your name, address, social security number (if an individual), assets, income and beneficiaries.
• Information about your transaction with us, or others; and
• Information we receive from a consumer reporting agency, government agencies, and from your agent banks and prime brokers where applicable, and from other sources, such as information concerning credit worthiness and history, and certain information requested pursuant to US Patriot Act anti‐money laundering prevention rules and regulations.
Anti‐Money Laundering – Customer Identity Verification
To help the government fight the funding of terrorism and money laundering activities, federal law requires broker‐dealer firms to obtain, verify, and record information that identifies each person who opens an account.
What Types of Information Need to be Provided
For an individual, When you open an account, we are required to collect information such as the following from you: Your name, date of birth, address, US Citizen identification numbers including taxpayer ID (social security or employer identification number) or non‐US Citizen identification numbers including taxpayer ID, passport number and country of issuance, alien identification card number, and a photograph of you. You may also need to show your driver’s license or other identifying documents.
For an entity, when an account is opened, we are required to collect information including documents showing the existence of the entity (such as a certified articles of incorporation, a government‐issued business license, a partnership agreement, or a trust instrument).
We may, under the following circumstances, rely on the performance by another financial institution (including an affiliate) of some or all of the elements of the customer identification process with respect to any customer that is opening an account or has established an account or similar business relationship with the other financial institution to provide or engage in services, dealings, or other financial transactions.
Such reliance is reasonable under the circumstances, when the other financial institution is subject to a rule implementing the anti‐money laundering compliance program requirements and is regulated by a Federal functional regulator and when the other financial institution has entered into a contract with us requiring it to certify annually to us that it has implemented its anti‐money laundering program, and that it will perform (or its agent will perform) specified requirements of the customer identification program.
Securities Investor Protection Corporation
Our firm is a member of the Securities Investor Protection Corporation (SIPC), which protects securities customers of its members up to $500,000 (including $250,000 for clams of cash). Explanatory brochure available upon request at www.sipc.org.
SEC Rule 17a‐3(a)(18) requires that we maintain a record indicating that each client or investor has been provided with a notice containing the address to which customers may transmit any complaints they may have respecting our firm. Additionally, our firm must ensure that customers are provided with a notice indicating the telephone number and the address at our firm to which such complaints may be directed. Please use the following address and phone numbers for customer complaints: CFR‐Inc., 18804 NE 106th St., Redmond, WA 98052 ‐ (425) 869‐6737 or (425) 869‐6701 Facsimile.
Business Continuity Plan
Pursuant to FINRA rules, our firm has created a Business Continuity Plan to address and guide our response to, and recovery from, Significant Business Disruptions (“SBDs”). Copies of this Summary Disclosure Statement are provided to all clients at the time they open their accounts with us. Our Business Continuity Plan is subject to modification and any updated summary will be annually sent to our clients. Alternatively, clients may obtain updated summaries by requesting a written copy by mail or facsimile.
In all of the following scenarios, the firm plans to continue business and our planned recovery time, depending upon the time of occurrence, should not exceed 24 hours from the time of the declaration of the SBD. Staff, telephone calls, and emails will return to their original location upon full restoration of service.
Disruption to a Single Building or our Firm’s Main Office
If a disruption occurs at our main office located at 18804 NE 106th St., Redmond, WA 98052, we will work from the nearest suitable, reasonably available office location, or allow staff to work from home offices.
Disruption to a Business District
If a disruption occurs in our business district, we will work from the nearest suitable, reasonably available office location, or allow staff to work from home offices. These locations shall be outside the business district.
City‐wide Business Disruption
If a disruption occurs in our city‐wide area that affects our main office, we will work from the nearest suitable, reasonably available office location, or allow staff to work from home offices. These locations shall be outside the city‐wide area.
If a regional disruption occurs that affects our main office, we will work from the nearest suitable, reasonably available office location, or allow staff to work from home offices.
Our firm has also contracted with various entities to insure that sensitive information is made redundant at back‐up facilities. However, due to the nature of such information, we do not disclose the specific location of any back‐up facilities, any proprietary information contained in our Business Continuity Plan or the parties with whom we have back‐up arrangements.
Please feel free to contact us if you have any questions.
President / Chief Compliance Officer
April 14, 2017