Telsey Advisory Group LLC (“TAG”) understands the importance of protecting your privacy. We are honored that you have placed your trust in us and we are committed to safeguarding the privacy of the information we maintain about you. Our policy is designed to explain what information we collect from you, how we use that information and how we protect the nonpublic personal information you have entrusted to us.
Information We Collect. While using our products or services, we may collect the following types of nonpublic personal information about you:
Information We Disclose. In order to support the financial products and services we provide to you, we may share the personal information described above with our staff, affiliates, representatives, their affiliated businesses, and third parties who provide you with financial products and services, which includes companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and marketing services.
These companies acting on our behalf are required to keep your personal information confidential.
Safeguarding Your Information. TAG maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information. Companies we use to provide support services are not allowed to use information about our clients for their own purposes and are contractually obligated to maintain strict confidentiality. We limit access to your information to those employees who are trained in the proper handling of nonpublic client information and who need access to the information to perform their job functions. This is to ensure full protection of all information you provide to us.
TAG has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us – If, after a significant business disruption, you cannot contact us as you usually do you should call our alternative number in San Francisco - (415) 354-2810. If the San Francisco office is your normal contact office you should call our New York office - (212) 973-9700.
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant 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.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within a two week time period. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within a two week time period. In either situation, we plan to continue in business, and notify you through how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
For more information – If you have questions about our business continuity planning, you can contact us at (212) 973-9700 in New York.
Order Execution Rule 606
The U.S. Securities and Exchange Commission's client disclosure rule, SEC Rule 606, requires all broker/dealers that route orders in equity securities to make available quarterly reports that present a general overview of their routing practices. The reports must identify the significant venues to which the client orders were routed for execution during the applicable quarter and disclose the material aspects of the broker/dealer's relationship with such venues.
The most recent such quarterly report for TAG can be found at the following link: http://www.tta.thomson.com/reports/
Important Information About Procedures for Opening a New Account>
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for information such as tax ID number and organizational documents that will allow us to identify your firm.
Broker Protection Principles.
i. TAG does not have any link between compensation for analysts and investment banking;
ii. TAG prohibits investment banking input into analyst compensation;
iii. TAG has a review committee to approve all research recommendations;
iv. TAG requires that upon discontinuation of research coverage of a company, TAG will disclose the coverage termination and the rationale for such termination;
v. TAG discloses in research reports whether it received or is entitled to receive any compensation from a covered company over the past 12 months; and
vi. TAG has established a monitoring process to ensure compliance with these principles.