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Send an Annual Privacy Notice to Clients

Under Regulation S-P under the Gramm-Leach-Bliley Act (GLBA), an investment adviser must provide an initial privacy notice to its customers at the time the advisory relationship is established and annually thereafter (unless the adviser qualifies for the exception from the annual privacy notice requirement described below).


Under Section 503(f) of GLBA, an investment adviser need not provide an annual privacy notice to customers if it provides nonpublic personal information only in accordance with the permitted disclosure provisions of GLBA and has not changed its policies and practices regarding disclosure of nonpublic personal information since the most recent privacy notice provided to its customers.