All information given to APA and all recommendations and advice furnished by APA to its clients will be kept confidential and will not be disclosed to anyone, except as APA may so agree in writing or as may be required to do so by law.
APA will collect non-public, personal information (NPI) about its clients as part of this engagement. This information will be obtained directly from the client and includes details such as the client’s date of birth, social security number, financial account numbers and balances, tax returns, sources and amounts of income, home addresses and telephone numbers.
As part of APA’s policy, APA restricts access to confidential personal information about its clients to those APA employees who need to know that information in order to provide products or services to its clients. APA maintains physical, electronic, and procedural safeguards to comply with federal standards to guard its clients’ confidential personal information.
Use of nonpublic information of former customers. The firm will provide nonpublic information about former customers only if required to do so by law or regulation or to those parties who need such information in order for the firm to carry out any continued obligation with respect to the services covered by the former adviser/customer relationship.
Should a client agree to accept financial advisory services provided by APA, APA may share the client’s NPI with non-affiliated third parties. APA may maintain agreements with various affiliated or non-affiliated entities who may act as the custodian and account holder for customers of APA and securities may be offered directly through those other broker-dealers properly engaged by APA. These third-party institutions may require agreements to establish a APA client’s account with them. APA will share only the appropriate customer NPI needed to facilitate these account agreements on behalf of its clients