SKBA CAPITAL MANAGEMENT, LLC
PRIVACY NOTICE
Under Securities and Exchange Commission regulations,
we are required to provide a notice to each of our individual clients that
explains our policies and practices relating to disclosing personal information
about you to our affiliates and to unrelated third parties. For your information, this requirement is
based upon an SEC regulation, called Regulation S-P, which applies to every
investment adviser that is registered with the SEC. As a general matter, it is (and always has
been) our policy not to disclose information about you to any other party, and
to maintain strict security over personal information about you in our
possession. We describe these
policies in further detail below.
What
are the categories of nonpublic personal information about you that we collect ?
We collect personal
information from you based upon the information that you have provided to us in
our Agreement for Investment Advisory Services, from information that we
collect when we effect transactions for you, and from on-going conversations
with you that allow us to provide asset management services to you based upon
your needs and goals. Some examples of
the information we collect relate to your financial condition including assets
under management, your tax situation and any other sensitive financial
data.
What
personal information do we disclose to others?
SKBA will share clients’
personal and nonpublic information only as necessary to manage clients’
accounts or at the request of its clients. Please refer to the above paragraph for examples of the information we
collect. SKBA does not share nonpublic
personal information with its affiliated entities except as it relates to
conducting business.
What
would your rights be if we did disclose your nonpublic personal information to
others?
If our policies were to
change and we sought to disclose your personal information to others, we could
not do this without your permission. Under those circumstances, you would have the right to opt-out of our
disclosing that information. In other
words, you would be able to tell us that we could not disclose the information
to any other person or entity. Since we
do not currently disclose any of your information to anyone other than those
previously mentioned, you do not need to avail yourself of the right to
opt-out. Should our policies change, we
would provide you with detailed information prior to implementing any potential change and request your
approval. At that time, we would also
provide you with information on how you would be able to opt-out of us
disclosing information about you.
How do we protect your nonpublic personal information that
we have in our files?
We have adopted strict
policies and procedures to protect your nonpublic personal information. For example, we restrict access to such
information to those employees who are involved, or assist others, in providing
you with asset management services; the client information in semipublic areas
is locked after normal business hours; we maintain a password protected
environment; and the firm has a policy to shred any unnecessary paper documents
for current or former clients which contain nonpublic personal information. All
employees are required to read and acknowledge receipt of our Code of Ethics
accepting our policy relating to confidential information.