Our Privacy Policy…

Privacy of Information is Serious Business!

In compliance with Federal Communication Commission regulations and in-line with SEC Regulation S-P and the intent of the Gramm-Leach-Bliley Act adopted by Congress in 1999, this notice describes the privacy policy and practices followed by Arlene Neff dba A. Neff Associates, Registered Investment Adviser. Privacy and confidentiality, along with accountability, are important component parts of the services we provide, so we welcome the opportunity to disclose our position on these and related business matters. We have worked hard to develop and maintain procedures that not only meet but also, in some ways, exceed the minimum standards of both past and present regulations.

Information Collected

Where does our information come from? The information we retain with respect to client affairs can come to us in one or both of the following ways.

• Data supplied by the client, or prospective client – verbally or in writing on information forms and applications. This data is focused on personal facts such as name, address, date and location of birth, marital status, sex, social security number, medical history, names and descriptions of dependents, financial goals, etc.
• Documents the client has caused to be delivered to us. Such documents take the form of statements of account for financial assets; transaction reports for investment accounts; copies of tax returns, trust agreements, wills, etc.

Please note – we would not solicit information about clients or prospective clients from other sources without requesting and receiving the individual’s specific permission to do so.

Information Disclosed

A. Neff Associates has not and will not disclose client information to third parties unless we are instructed to do so by the client or are required to do so by a court of law or under the terms of Securities and Exchange Commission or National Association of Security Dealers regulations.

Confidentiality and Security of Our Client’s Personal Information

We maintain a secure office and computer environment to ensure that no information, be it client-oriented information or our own privileged company information, is exposed to avoidable risk or corruption.

Only employees with a valid business reason have access to any of the information we retain in any form -- hard copy or electronic. All persons who come in contact with client information are educated on the importance of maintaining the confidentiality and security of that information -- both during their term of employment and afterward. In addition, all employees are required to acknowledge their understanding of their confidentiality obligation in writing at the time of initial employment. Employees are also required to constantly demonstrate their willingness to abide by our information handling practices.

Rather than rely solely on electronic and procedural safeguards to assure the confidentiality and integrity of client information in our possession, we have segregated and secured our computer equipment and information systems according to their use to further control access.

As a final precaution, we shred all hard copies of documents containing client information and destroy all data storage media before disposal.

Privacy Issues for Further Consideration...

We believe that the extra cost and effort required to maintain exclusive access to any and all of the data, programs and systems we depend upon in our work is warranted. We believe that the cost of preventing a problem is insignificant when compared to the cost required to attempt to repair damage that could result from negligence.

Information About Former Clients

Nonpublic information about both prospective and former clients is also maintained on a confidential and secure basis by A. Neff. Associates. If any disclosure were to be made, it would be for the reasons and under the conditions described in this notice. We do not disclose any nonpublic personal information about prospective or former clients except as required by law.

While we recognize and respect the privacy concerns of potential, current and former clients, and are committed to safeguarding all personal information in our possession, it is necessary to recognize that we can only control the data and information that is in our possession.

In those situations where we find ourselves working in concert with other businesses or organizations also engaged by a client in the management of the client’s financial affairs, it remains the client’s responsibility to determine that the privacy policies of those other businesses or organizations also meet or exceed the client’s expectations.