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. TFG requires that our affiliates protect and restrict the use of client information to the same extent as TFG.
TFG Clientele: Your privacy is a serious matter to us. This Privacy Notice is presented annually to our TFG 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. TFG’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
TFG’s computer system consists of a peer-to-peer network including a server, which stores all data related to client activities. All TFG 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 TFG computers are regularly scanned for viruses. TFG 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
E-mail: From time to time, TFG will correspond with clients regarding private matters via electronic mail. TFG takes the precaution of verifying all client e-mail addresses, and limiting 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 e-mail which addresses any persons who may receive the message in error, along with instructions to contact our office and properly dispose of the data. E-mail communications to third parties which relate to our clients are conducted only as necessary to fulfill the obligations of the firm; however, no personal information pertaining specifically to our clients is shared with third parties without the expressed consent of the client.
Phone: Client communications by phone are a daily task, and in situations where TFG 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 our 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: TFG now offers a password secured online portal for information, communication, and document delivery between TFG and its clients. This portal is accessed through TFG’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 e-mail, internet, and telephone. TFG is aware of this threat, and it is our 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 TFG’s custom to cultivate personal relationships with its third-party affiliates, which greatly helps us identify impostors.
Regular Mail: It is TFG’s policy to never mail personal and sensitive information regarding a client other than to the address kept on record at TFG, without the client’s expressed instruction.
Security Among Third Parties
Daily Business Operations: TFG 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. TFG routinely reviews these practices to ensure the confidentiality, security and integrity of its nonpublic personal information.
Third-Party Service Providers: TFG 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 to us. For example, TFG requires regular services from computer technicians. Therefore, we obtain a signed non-disclosure acknowledgement and agreement from each service person, which explains our policy of client privacy and holds the third-party individual to the same standards of protection.
The 2005 FACT Act requires proper destruction of confidential client information entrusted to Investment Advisers. TFG 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, and destruction is certified and documented by the company with each call.
Cyber Security: Protecting You and Your Money
Whether it’s the Equifax hack or you accidentally downloaded a virus from a scam email, cyber threats are out there and they are not going away. We know you want to do everything you can to keep your hard-earned money safe. We at TFG are your partners in safety and want you to know…
What We Are Doing To Help You Sleep Better At Night:
- Charles Schwab has the Schwab Security Guarantee, which states that Schwab will cover 100% of any losses in any of your Schwab accounts due to unauthorized activity. Schwab, our custodian, has also confirmed that the recent Equifax incident is not related in any way to Schwab data or their systems.
- TFG has 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.
- We know “How to Respond to a Data Breach.” And if you read this step-by-step urgent-response guide, you will be ready for the unthinkable too.
- Communicating: Make sure you follow us on Facebook and/or Twitter, and add [email protected] to your address books. We will send out alerts on important announcements, educational webinars, and other resources through these avenues.
- TFG 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
- 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.)
- 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.)
- 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.
- 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.*
- 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.
- Change Passwords Regularly: Make each password unique, long, and strong, and use two-factor authentication when available.
- If You Ever Suspect Fraudulent Activity On Your Accounts:
- Call Schwab immediately at 1-800-515-2157
- 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!
Last Reviewed: 10/04/17
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Tull Financial Group Firm Brochure
We are committed to serving our clients with the highest fiduciary and ethical standards.
Our Firm Brochure (formally called the Form ADV II Brochure) is a document that describes all 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 Security and Exchange Commission’s (SEC) website: www.adviserinfo.sec.gov