Business Continuity Plan
SUMMARY OF BUSINESS CONTINUITY PLAN
Moseley Investment Management specifically has developed a Business Continuity Plan. In accordance with this rule, MIM has developed a plan to ensure that we can continue to run our business during periods of business emergencies. 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.
If after a significant business disruption, you cannot contact us as you usually do at (941) 745-2799, you should call 941-224-3907, 941-704-7569 or 727-422-7658. You can also contact us through our web site at www.moseleyinvestment.com. If you cannot access us through either of those means, you should contact your custodian, TD Ameritrade at 800-431-3500 or Schwab 800-515-2157 for instructions on how they may assist you in accessing your accounts.
OUR BUSINESS CONTINUITY PLAN
Our business continuity plan addresses: data backup 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.
Our custodian’s TD Ameritrade and Charles Schwab & Co. back up important account records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within specified times as mandated by the Securities Exchange Commission, NYSE, and FINRA. Your orders and requests for funds and securities could be delayed during this period.
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 times specified by the Securities Exchange Commission, NYSE, and FINRA. 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 businesses in a timely fashion with emphasis on recovery of critical functions according to their time criticality. In either situation, we plan to continue in business, transfer operations to our custodians if necessary, and notify you through email, telephone call, social media, or our website www.moseleyinvestment.com on 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 (941) 745-2799 or e-mail firstname.lastname@example.org.
Please be advised that business continuity plans are subject to change. Moseley Investment Management, Inc. intends to update and test its business continuity plan at least annually, and as business conditions and technology changes.
Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Moseley Investment Management, Inc.
INFORMATION WE COLLECT
In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, which may include:
- Social Security number and date of birth
- Employment Information, income and financial goals
- Types of accounts, account balances and assets
- Credit history and credit scores
- Contact information such as names, address, telephone number and email
- Family information
CATEGORIES OF PARTIES FOR WHOM WE DISCLOSE
We will not disclose information regarding you or your account with us, except under the following circumstances:
- To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company.
- To third parties who perform services or marketing on our behalf.
- To your attorney, trustee, accountant or anyone else who represents you in a fiduciary capacity.
- To our attorneys, accountants or auditors.
- To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquires.
We do not sell customer lists or customer information to third parties.
HOW WE USE INFORMATION
Information may be used among the affiliate companies that perform support services for us, such as data processors, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as:
To protect your accounts from unauthorized access or identity theft.
To process your requests such as securities purchases and sales.
To establish or maintain an account with an unaffiliated third party such as a clearing broker-dealer providing services to you and or Moseley Investment Management.
To service your accounts, such as issuing checks and account statements.
To comply with Federal, State and Self-Regulatory Organization requirements
To keep you informed about financial services of interest to you.
OUR SECURITY POLICY
We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain procedural security measures to safeguard confidential client information.
OPT OUT PROVISION
If, at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, Moseley Investment Management will give its clients advance notice of the proposed disclosure so that they will have the opportunity to opt-out of such disclosure, as required by applicable law.
CLOSED OR INACTIVE ACCOUNTS
TO WHOM THIS POLICY APPLIES
This Privacy applies to individuals who obtain or have obtained services from Moseley Investment Management, Inc.
OUR SECURITY PRACTICES INFORMATION ACCURACY
We take steps to safeguard client information. We restrict access to the personal and account information of our clients to our employees and agents for business purposes only. We maintain physical, electronic and procedural safeguards to guard your personal information.
CHANGES TO THIS POLICY
If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.