Privacy of Consumer Financial Information

Miller-Green Financial Services, as a Registered Investment Advisory Firm is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and in conjunction with the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”).  Miller-Green Financial Services is therefore subject to the rules of privacy imposed under the Act and the SEC Rule.   

The Rule requires every broker, dealer, investment company, and registered investment adviser to adopt policies and procedures reasonably designed to safeguard customer records and information.  Miller-Green Financial Services maintains compliance under the Act.  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 your transactions, accounts, trading activity and parties to transactions, health and beneficiary information (insurance services); 

• Information from other outside sources; 

• Any other information that is deemed to be nonpublic personal information as defined by the Gramm-Leach-Bliley Act and by the Securities and Exchange Commission’s Privacy Act, Regulation S-P.

 The Representatives and Associated Persons of Miller-Green Financial Services realize that the sharing of nonpublic personal information is an act of trust and take this issue very seriously.  All information provided by clients to Miller-Green Financial Services, (including the Adviser’s Associated Persons), and information and advice furnished by the Adviser to clients, shall be treated as confidential and shall not be disclosed to non-affiliated third parties, except as permitted by clients with written authorization, or as required by any rule, regulation or law of any regulatory or self–regulatory organization of which Miller-Green Financial Services or its Associated Persons may be subject.   

It is the policy of the Adviser to restrict access to records to only those associates who need to have such information in order to deliver the investment advisory or administrative services of the Adviser.  The Adviser secures its offices during non-business hours.   

Miller-Green Financial Services is required to maintain records for five years after the termination of services as required by regulators.  Therefore, former clients receive the same protection of information as current clients.  After the storage time period has expired, records are destroyed via in-house shredding.   

Consumers may provide nonpublic personal information to Miller-Green Financial Services but may never become clients.  In these cases, the Adviser will promptly return any requested information or will maintain the information on file for a period of up to five years before destroying the material via in-house shredding.  In such cases, these records receive the same privacy protection as our existing and former clients. 

Miller-Green Financial Services seeks only to work with those financial services firms who share our privacy policy.  However, it is the responsibility of clients to seek the written privacy policies and procedures of non-affiliated firms they seek to do business with during the course of investment advisory services. 

Clients are welcome to discuss any questions or concerns regarding the Adviser’s privacy policies and procedures directly with Don Gilbert, the Chief Compliance Officer of the Adviser.