Privacy Policy

MBAM, LLC (a/k/a Miles Brown Asset Management, LLC “MBAM”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, MBAM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of MBAM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client.

MBAM may disclose the client’s information if MBAM is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with MBAM, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by MBAM in order to facilitate the commencement, continuation, termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for MBAM (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

MBAM permits only authorized employees and affiliates who have signed a copy of MBAM’s Code of Ethics (or other document providing substantially similar terms) to have access to client information. Employees violating MBAM’s Code of Ethics will be subject to MBAM’s disciplinary process. Additionally, whenever MBAM hires other organizations to provide services to MBAM’s clients, MBAM require them to sign confidentiality agreements or their respective agreement will contain confidentiality provisions.

 

Our Business Continuity Plan

We plan to quickly recover and resume business operations after a business disruption of any sort. Our first priority will be the safety of our employees and the privacy of your personal information. In addition, we will take immediate steps to safeguard our property, make a financial and operational assessment, protect the firm’s books and records, and take necessary steps to allow our customers to transact business as normal. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, dependent upon the scope and severity of the business disruption.

Our business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore their own operations and be able to process necessary transactions within one day. Your orders and requests for funds could be delayed during this period.

 

Legal

No Solicitation

This Website is for informational purposes only and does not constitute an offer to sell or the solicitation of an offer to purchase any security or investment product or services. The content of this Website is provided solely for your personal use and shall not be deemed to provide access to any particular transaction or investment opportunity. MBAM does not intend the information on this Website to be investment advice, and the information presented on this website should not be relied upon to make an investment decision.

The information provided on this Website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject MBAM, its affiliates, employees, directors, officers or agents to any registration requirement within such jurisdiction or country.

Disclaimer of Warranty and Limitation of Liability

The content of this website is provided “as is” without warranty of any kind (express or implied). MBAM does not assume any obligation to update the information and data on this website and does not guarantee that it is accurate, current, valid, complete or suitable for any particular purpose.

MBAM makes no representations concerning this website, or to any websites to which this website may be linked and disclaims all express, implied and statutory warranties of any kind, including warranties of merchantability, non-infringement or fitness for a particular purpose, to the fullest extent allowed by applicable law. In no event shall MBAM or any of its affiliates, manager members, members, partners, directors, officers, employees, or other representatives be liable or have any responsibility of any kind for any direct, indirect, special, consequential, multiple, punitive or other damages arising from information on this website or the use of this website.

Our Custodians

These materials have been independently produced by MBAM. MBAM is independent of and has no affiliation with our custody and clearing firms. Our custody and clearing firms have not created, supplied, licensed, endorsed, or otherwise sanctioned these materials nor have conducted any independent verification of the facts and representations underlying these materials.