While information is the cornerstone of our ability to provide superior service, our most important asset is our clients trust. Keeping client information secure is a top priority for all of us at Empire State Financial, Inc. In the operation of the investment services provided by Empire State Financial, Inc., Empire State Financial, Inc. collects and maintains certain information regarding its clients. In order to best service our clients and determine suitable investment and or insurance strategies, we must have certain information, such as income, net worth, risk tolerance, investment objectives and insurable interests.
This information is obtained primarily from the account paperwork and applications that you, the client are required to fill out, and from communication between the broker and the client, or between the administrative support staff and the client.
In an addition our tax reporting requirements require us to have certain information such as name, address, and social security numbers, or tax ID numbers.
To whom do we disclose information:
Empire State Financial, Inc. discloses personal information only to the broker and/or brokers who are working with the account, as well as the administrative staff required to facilitate the processing of paperwork or other functions related to the account. In addition, management and compliance officers as required to fulfill their respective obligations.
Empire State Financial, Inc. has contracted with BB Graham & Co. and RBC Clearing & Custody, a division of RBC Capital Markets Corporation, to clear trades. RBC Clearing & Custody and BB Graham will be provided only that information that is necessary to establish, process and maintain the account. RBC Clearing & Custody and BB Graham will use this information as necessary to service the account, and will not use it for marketing purposes.
Empire State Financial, Inc. may have numerous selling agreements with mutual funds and insurance carriers and will share only information necessary to establishing, processing and maintaining the account.
Categories of information that we disclose:
In order to open and maintain your account, held at our Clearing Firm, a Mutual Fund, or Insurance Company, Empire State Financial, Inc. may be required to disclose certain types of information to such entities. This information may consist of the name of all persons or entities, having ownership, control, or beneficial interest in such account, social security numbers and/or tax ID numbers, date of birth, the address or addresses or such persons or entities, phone numbers, place of employment, income and net worth information, investment objectives, and in the case of corporate or trust accounts, we may need to provide documentation of such corporation, partnership, sole proprietorship, limited liability company, or any other type of corporate entity, or trust, as well as who is authorized to act on behalf of such corporate entity or trust, and what types of investments that they are permitted to make. In the case of Qualified Retirement Plans, and Insurance Plans, we may also be required to provide information on beneficiaries of such plans, with names, addresses, Social Security Numbers, and date of birth of beneficiaries, and may need to provide a spouse's signature in community property states. Any information provided to us on the forms that you fill out to open the account, may need to be provided to the Clearing Firm, Mutual Fund Company, or Insurance Company. In order to process wire transfers, the Clearing Firm, Mutual Fund Company or Insurance Company require information regarding the account from the money is being wired out, or the account which the money is being wired into.
Empire State Financial, Inc. will also make such information available where it is required by law or regulation. This includes court orders, response to a subpoena, or regulatory demand.
Empire State Financial, Inc. will also make such information available as authorized by the client, such as a request for duplicate statement or trade confirmations to a third party.
Empire State Financial, Inc. may make certain account information available to lenders to verify credit worthiness, provided the client has provided written authorization to the lender to verify such information.
Empire State Financial, Inc. does not provide any information to mailing lists or marketing organizations.
If you wish us to provide trade information or other information to a third party, such as an accountant at tax time, please notify your Empire State Financial, Inc. representative ahead of time in writing that such a person will be calling.
In regards to former customers of Empire State Financial, Inc., your information will not be provided to any outside organization, except by your request, or where it is required by law or regulation, including court orders, response to a subpoena, or regulatory demand.
Empire State Financial, Inc. will at all times take whatever measures reasonable and necessary to protect the confidentiality, security, and integrity of your nonpublic personal information. None of your information will be disclosed to any outside sources, except as described as above, and only internally to the extent that such information is necessary to service your account, or review your account for regulatory compliance, and only to such brokers, compliance, or administrative staff involved in such servicing of the account, to the extent that such information is necessary to do so.