This informational notice covers how Beaumont Financial Partners, LLC and its separate division, Beaumont Capital Management, (collectively “Beaumont”) safeguards your nonpublic personal financial information.
At Beaumont, protecting the privacy of client information is one of our fundamental responsibilities. This notice summarizes our policy regarding the confidentiality and disclosure of client information. We do not sell or rent any personal information we gather from you to anyone, and will only share such information with others in the normal course or business or as stated in this notice.
Personal Information Collected
As a client of Beaumont, you have provided, or may provide in the future, personal and non-public information about you and your family to Beaumont. Some examples of the information we may collect, request or disclose include:
- Name, address, phone number, social security number, tax identification number and date of birth.
- Assets, employment history, income, liabilities, retirement goals and legal documents.
- Account balances, account numbers, statements and custodians.
- A photo copy of a valid driver’s license, passport, green card or military identification. Such identification may be required by Beaumont and/or the custodian when opening new investment accounts. Many financial institutions in the United States require a copy of at least one of these documents to comply with Uniting and Strengthening America by Protecting Appropriate Tools Required to Intercept and Obstruct Terrorism, also known as the USA PATRIOT Act.
Beaumont may also receive information from the custodians used for client accounts or other custodial firms including:
- Duplicate copies of monthly statements and trade confirmations
- Daily electronic downloads of clients’ account information (e.g. all transactions and positions).
Before a custodian distributes the above information to Beaumont, the client will likely be required to provide authorization to the custodians (usually part of the account application process) to do so.
Why We Collect Personal Information
The personal information we collect is necessary to help us provide informed investment management, financial planning and/or tax services to you.
How We Handle Your Personal Information
As emphasized above, we do not sell, rent or distribute information about current or former clients, their family or their accounts to third parties. However, information may be shared with 3rd parties as needed in the normal course of business, such as to: open accounts, meet required compliance reviews and security measures, or complete transactions in your accounts.
- In order to open accounts or complete transactions for you, it may be necessary to provide aforementioned identifying information to custodians, companies, individuals, or groups not affiliated with Beaumont. In addition, Beaumont may be asked to provide its custodians with copies of our Investment Advisory Agreement with you.
- At times, we will have 3rd party relationships (such as our IT provider, CPAs for tax preparation and an independent class action recovery company) that will have access to a portion or all of our client data. During the course of these relationships, these firms will have access to information that we have collected from our clients. In these instances, we only release the information that is necessary for the third party to complete its assigned responsibilities (i.e. tax cost basis, holdings, etc.), conversely our IT provider will have virtually full access to our client data. We require that these third parties treat your personal information with the same high degree of confidentiality as Beaumont.
- For clients with a Beaumont Capital Management (BCM) account, Beaumont has hired Envestnet Asset Management, Inc. to handle many of the back-office functions (i.e. opening new accounts, trading, billing and reporting) for BCM. As a result, Beaumont will need to provide confidential BCM client data to Envestnet to complete these back office services.
It is always our intent to protect and maintain the integrity of any client information collected or received during the course of the relationship. Beaumont has contractual agreements with third parties used stipulating the limitations of any information to which they may have access. In short, all non-public client information should be kept confidential and not shared, sold, copied or otherwise used. However, Beaumont clients have the option to opt-out of having their information shared with any third parties. If you would like to opt-out of having your information shared please contact your relationship manager or call the number at the end of this notice.
Confidentiality and Security Procedures
How You Can Protect Your Information
If you access your accounts on-line, you should confirm that the anti-virus software and firewall/spyware protection is current on the computer(s) that you use to access your accounts. We also strongly recommend that you select a unique User ID and Password that does not contain any personal information (i.e. SSN, DOB, Name, phone #, etc.) and changing the password periodically. Additionally, we recommend that you do not provide any of your account information, including online account user names or passwords, to anyone. This is especially important if the request is presented via email or over the phone by a source that you are not familiar with. It is also suggested that you regularly review the activity on your brokerage statements. If you notice any suspicious or irregular activity relating to your account(s), or if you feel any of your information has been compromised, hacked or otherwise obtained, please contact us immediately.
Massachusetts law (Sec. 203A) requires disclosure that information on disciplinary history and the registration of the adviser and its associated persons may be obtained by contacting the Public Reference Branch of the U.S. Securities and Exchange Commission at (202) 551-8090 or the Massachusetts Securities Division, One Ashburton Place, 17th Floor, Boston, Massachusetts 02108 or (617) 727-3548.
COMPLIANCE WITH PRIVACY REQUIREMENTS
In compliance with 201 CMR 17.00 Beaumont has a designated Information Security Manager and maintains a Written Information Security Program (WISP). This Program, as required by the Commonwealth of Massachusetts, includes detailed information about how client information collected by Beaumont is protected. It outlines the responsibilities of the firm and its personnel to protect client data. Although the requirement only pertains to residents of Massachusetts, the standard is applied to all clients. Beaumont is also aware of and may consider the stipulations set forth by each state. In addition, Regulation S-P provides further guidance and requirements for handling and protecting non-public client information (NPI) which are also applied by Beaumont and have been incorporated into our WISP.
NOTIFICATION OF BEAUMONT FINANCIAL PARTNERS, LLC’SPROXY POLICY
In accordance with SEC Rule 206(4)-6 of the Investment Advisers Act of 1940 relating to Proxy Voting, the Beaumont Proxy Policy states: As a matter of current policy, Beaumont Financial Partners, LLC, does not vote proxies on behalf of its clients. While all Beaumont’s Investment Advisory Agreements grant the firm the legal ability to do so, we are not required to exercise that ability. If our current proxy policy changes, we will promptly notify our clients.
ANNUAL FORM ADV OFFERING
Federal law, through the U.S. Securities and Exchange Commission (SEC), requires Beaumont Financial Partners, LLC to provide the following offer annually:
Per Rule 204-3 of the Investment Advisor’s Act of 1940 an investment advisor is required to annually, within 120 days of its fiscal year end, deliver to existing clients either (1) a complete, Disclosure Document (Form ADV, Part 2A) or (2) a summary of material changes to the Disclosure Document since the last update and also offer to provide a copy of the full Document upon request, without charge. If at any time you would like a complete copy of our Disclosure Document, please call or write, using the following information, and we will be sure to send you a copy.
Beaumont Financial Partners – 250 1st Avenue, Suite 101 – Needham, MA 02494 – (781) 400-2800.
You do not need to call or do anything as a result of this notice, however please contact us if you have any questions.