Disclosures

Also Read: Cybersecurity: Protecting You and Your Money

Tull Financial Group is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended. Tull Financial Group maintains a Privacy Policy in order to comply with the SEC’s Privacy of Consumer Financial Information rule (Regulation S-P).

Tull Financial Group’s Privacy Policy applies to any individual to whom Tull Financial Group renders financial services or has done so in the past (in other words, all clients of Tull Financial Group). It covers any nonpublic personal information obtained from clients as well as from other firms in connection with providing such services. The categories of nonpublic personal information collected depend on the scope of the client engagement, and may include descriptions of clients, Social Security numbers and birth dates, contact information, income and asset information, employment details, tax and estate documents, transactions between clients and third parties, other financial information, and health information.

All nonpublic personal information is treated as strictly confidential and is not disclosed except to employees for the purpose of carrying out their responsibilities and to affiliated and nonaffiliated firms necessary to affect and administer custodial, brokerage, financial planning, legal, accounting, insurance or similar services requested and authorized by the client. Federal and state regulators also may review client records as permitted under law. Tull Financial Group requires its affiliates protect and restrict the use of client information to the same extent as Tull Financial Group.

Tull Financial Group Clientele: Your privacy is a serious matter to us. We present the Privacy Policy at least annually to our clients to demonstrate that every effort is being made to secure all private client information from public access.

Secured Paper Files

Filing cabinets are locked outside of regular business hours. Any papers to be disposed which contain client information are shredded on-site monthly by a bonded and insured company. Tull Financial Group’s site of business is also securely locked and electronically armed for fire and theft outside of regular business hours.

Secured Electronic Files and Databases

Tull Financial Group’s computer system consists of a peer-to-peer network, including a server that stores all data related to client activities. All Tull Financial Group computers are secured by a password system, and all workstations are logged off outside of regular business hours. Any electronic information accessible through the Internet is guarded by a secure firewall, and all Tull Financial Group computers are regularly scanned for viruses. Tull Financial Group backs up all electronic data essential to its operations on a daily basis with the prior day’s backup electronically sent and stored to a remote location in case of disaster.

Secured Client Communications

Email: From time to time, Tull Financial Group will correspond with clients regarding private matters via electronic mail. Tull Financial Group takes precautions to verify all client email addresses and limits the content of communications to exclude sensitive elements, such as account numbers, Tax ID numbers, and the like, unless authorized by the client. A disclosure is included with every client email, which addresses any persons who may receive the message in error along with instructions to contact Tull Financial Group’s office and properly dispose of the data. Email communications to third parties which relate to clients are conducted only as necessary to fulfill the obligations of the firm; however, no personal information pertaining specifically to clients is shared with third parties without the expressed consent of the client.

Phone: Client communications by phone are a daily task. In situations where Tull Financial Group initiates a call and reaches voicemail, the policy is to limit the content of information to exclude dollar amounts, account numbers, and any other sensitive information, unless authorized by the client. Conversations occurring with third parties related to client situations are conducted only as necessary to fulfill the obligations of the firm; however, no personal information pertaining to clients is shared with third parties without the expressed consent of the client.

ClientView Live: Tull Financial Group now offers a password-secured online portal for information, communication, and document delivery between Tull Financial Group and its clients. This portal is accessed through Tull Financial Group’s website.

Phishing: “Phishing” is the illegal attempt to trick people into providing personal, confidential or financial information. For example, a person falsely claiming to be a person of authority may contact an office to request private client information with the intent to use the information for identity theft. These malicious attempts may come through email, Internet, and telephone. Tull Financial Group is aware of this threat, and it is its practice to: (1) validate the identity of any individual requesting such confidential information; (2) clarify the reason for the request; and (3) establish that the client has granted authorization before releasing the requested information. It is also Tull Financial Group’s custom to cultivate personal relationships with its third-party affiliates, which greatly helps identify impostors.

Regular Mail: It is Tull Financial Group’s policy to never mail personal and sensitive information regarding a client other than to the address kept on record at Tull Financial Group without the client’s expressed instruction.

Security Among Third Parties

Daily Business Operations: Tull Financial Group and its employees avoid leaving nonpublic personal information in plain view in areas where it may be seen by visitors or discussing such information in public places where it may be overheard. Tull Financial Group routinely reviews these practices to ensure the confidentiality, security and integrity of its nonpublic personal information.

Third-Party Service Providers: Tull Financial Group employs the services of third parties who either have direct access to confidential information or may inadvertently come across it within the proper capacity of their services. For example, Tull Financial Group requires regular services from computer technicians. Therefore, the firm obtains a signed non-disclosure acknowledgement and agreement from each service person, which explains Tull Financial Group’s policy of client privacy and holds the third-party individual to the same standards of protection.

Document Destruction

The 2005 FACT Act requires proper destruction of confidential client information entrusted to Investment Advisers. Tull Financial Group utilizes a bonded and insured destruction service, which calls monthly and destroys all materials on-site. Materials awaiting destruction between calls are held in a locked bin. Destruction is certified and documented by the company with each call.

Ongoing Diligence

Tull Financial Group’s Privacy Policy is reviewed at least annually to ensure our efforts to protect client privacy remain current with ongoing changes experienced within this profession through technological advancements and other various influences.

Whether it’s an Equifax hack or an accidental downloading of a virus from a scam email, cyber threats are present and are not going away. Tull Financial Group knows you want to do everything you can to keep your hard-earned money safe, and we are your partners in safeguarding your accounts and privacy of information.

What We Are Doing To Help You Sleep Better At Night:

1. Charles Schwab, our custodian, offers the Schwab Security Guarantee, which states Schwab will cover 100% of any losses in any of your Schwab accounts due to unauthorized activity.
2. Tull Financial Group maintains a strict Security Policy, which covers everything from passwords for online access, to phone calls, to paper files and shredding. We are also proactive and diligent in learning and applying the latest methods to keep your information safe.
3. Tull Financial Group knows “How to Handle Fraud or Identity Theft.” If you read this step-by-step urgent-response guide, you will be ready for the unthinkable, too.
4. Tull Financial Group actively communicates with clients. Make sure to follow us on Facebook, X, and LinkedIn, and add TFG@TullFinancial.com to your address book. We regularly send out alerts on important announcements, educational webinars, and other resources through these avenues.
5. Tull Financial Group is a Fiduciary. We put our clients’ best interests first at all times, and are here to help you if you ever suspect that you’re a victim of identity theft.

The Equifax Hack: What Steps to Take

1. See If You Were Impacted: Over 143 million consumers were exposed, revealing personal information like social security numbers, birth dates, and even credit card info. Click here and provide your last name and last six digits of your SSN to see if you were impacted. (Keep in mind that being “impacted” only means that hackers had access to your information, but it does not necessarily mean that your accounts have been directly hacked. It does mean that you are at risk.)
2. Consider Credit Monitoring: Equifax did provide one year of free credit file monitoring through TrustedID, but enrollment expired on January 31, 2018. There are other similar services you could purchase that are not connected with Equifax, such as LifeLock and Identity Force. Here is a comparison chart of some of these services, in case you want to consider purchasing one. (TFG is not affiliated with any of these services.)
3. Consider Adding A Fraud Alert: A temporary action would be to put a Fraud Alert on your credit reports for free by contacting one of the credit agencies (for example, you can do it online through Experian), which is required to notify the other two bureaus, so you only have to request it once. An initial fraud alert can make it harder for an identity thief to open more accounts in your name. When you have an alert on your report, a business must verify your identity before it issues credit, so it may try to contact you. The initial alert stays on your report for 90 days. You can renew it after 90 days, but renewal is not automatic — you must request it again. It allows you to order one free copy of your credit report from each of the three credit reporting companies.
4. Consider Doing A Credit Freeze: A preemptive move would be to put a Credit Freeze on your credit report with each of the main credit bureaus (Equifax, Experian, TransUnion.) First read about it here to see if it’s right for you. For the freeze to be fully effective, you should also place a freeze on your Experianand TransUnion accounts. Executing a freeze with one credit bureau will NOT automatically update the others, so you must do them individually. Be aware, though, that if you need to apply for credit or loans, you will have extra steps to go through to lift or remove the freezes. (There are differing opinions on freezes, as it could cause a lot of hoop-jumping should you ever need to apply for new credit/loans yourself. However, if you rarely apply for new credit/loans, then a freeze might be useful to you.) Then see item #4 at the bottom of page 2 of “How to Respond to a Data Breach” for details on how to do this. *Read this for the difference between Fraud Alerts and Credit Freezes.*
5. At Minimum, Monitor Your Accounts Regularly: Check your monthly statements. Keep an eye on your FICO score for changes, which can often be done through your existing credit card accounts or through a free service like Credit Karma. Get a free credit report every year. Be vigilant.
6. Change Passwords Regularly: Make each password unique, long, and strong, and use two-factor authentication when available.
7. If You Ever Suspect Fraudulent Activity On Your Accounts:
   1. Call Schwab immediately at 1-800-515-2157
   2. Call TFG immediately at (757) 436-1122 or (888) 296-7526 toll free.

Be aware that all these things are optional and giving anyone your personal information for any reason — even if it’s meant to safeguard your personal information! — can carry a risk of more exposure. However, we are doing our best to keep up with all the information available and rule out the noise, and we will update this page accordingly.

We welcome your questions at any time, and are happy to help you in your quest for security and peace of mind. Together we can succeed at thwarting cyber criminals!

These websites are for informative purposes only, and are not to be construed as tax, legal, or investment advice. By clicking on the links above, you are leaving Tull Financial Group’s website. These websites are not affiliated with nor monitored by Tull Financial Group. This article is provided for general information only, and nothing contained in the material constitutes a recommendation for purchase or sale of any security or investment advisory services. Reproduction of this material is prohibited, and all rights are reserved. Read the full Disclosure.

Tull Financial Group is a SEC registered investment adviser located in Chesapeake, Virginia. All Tull Financial Group representatives are in compliance with current registration and/or notice filing requirements imposed upon SEC registered advisers.

The purpose of this website is to provide information about Tull Financial Group’s professional services and to offer a means for contacting the firm. It does not constitute a solicitation or offer to sell securities or investment advisory services. Advice can only be rendered after a person has been provided Tull Financial Group’s Form ADV Part II and upon the execution of an Investment Policy Statement and a Managed Account Agreement or Financial Planning Contract between parties. Tull Financial Group will not effect, or attempt to effect, transactions in securities, or render personalized investment advice for compensation over the Internet.

Tull Financial Group does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Tull Financial Group’s website or incorporated herein, and takes no responsibility thereof. All such information is provided solely for convenience purposes only, and all users thereof should be guided accordingly. All material presented is compiled from sources believed to be reliable however, accuracy cannot be guaranteed.

Clicking on any links contained in this website may lead you away from Tull Financial Group’s website. These websites are not affiliated with nor monitored by Tull Financial Group. Third-party websites linked to Tull Financial Group’s website are for informational purposes only, and are not to be construed as tax, legal, or investment advice.

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The material in this newsletter is provided for general information only, and nothing contained in this newsletter constitutes a recommendation for purchase or sale of any security or investment advisory services. The articles linked in our newsletter come from many sources and are provided for informational purposes only. With the exception of www.TullFinancial.com, the websites and organizations listed in this newsletter are not affiliated with nor monitored by Tull Financial Group, and are not to be construed as tax, legal, or investment advice.

All material presented is compiled from sources believed to be reliable, however, Tull Financial Group does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, and takes no responsibility thereof. Copyright for linked articles belongs to the linked source.

This newsletter and all the material contained within is intended for personal use only. Reproduction of this material for public distribution is prohibited, and all rights are reserved. View the Firm Brochure for additional information about how Tull Financial Group conducts business as a Registered Investment Advisor.

We are committed to serving our clients with the highest fiduciary and ethical standards.

Our Firm Brochure (formally called the Form ADV Part 2A) is a document that describes the details of how we conduct business as a Registered Investment Advisor. Clients and other interested parties are welcome to review or request a copy of our Firm Brochure at anytime, and our clients always receive a copy when they initially engage us as their Advisor. You may also view our Firm Brochure online at the U.S. Securities and Exchange Commission’s (SEC) website.