This website is limited to the dissemination of general information regarding the investment advisory services of Westfuller Advisors, LLC (“Westfuller”) to United States residents residing in states where providing such information is not prohibited by applicable law. Westfuller does not offer its services to Individuals of the EU. Accordingly, the publication of this website is not be construed by as a solicitation to effect, or attempt to effect, transactions in securities. Nothing on this website is to be construed as the rendering of personalized investment, legal or tax advice. Westfuller does not make any representations as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to this website or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.
Westfuller is an SEC registered investment adviser with a principal place of business located in New York, New York. Westfuller may only transact business in those states in which it is notice filed, or qualifies for an exemption or exclusion from notice filing requirements. Any subsequent, direct communication by Westfuller will be initiated by a representative that is either registered, or qualifies for a corresponding exemption, in the state in which the client resides. For additional information pertaining to the registration status of Westfuller, please refer to the Investment Advisers Public Disclosure website at www.adviserinfo.sec.gov. A copy of the Westfuller current written disclosure brochure, as set forth on Part 2A Form ADV, discussing the firm’s business operations, services, and fees is available from Westfuller upon written request.
ACCESS TO THIS WEB SITE IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND WITHOUT ANY WARRANTIES, EXPRESSED OR IMPLIED, REGARDING THE ACCURACY, COMPLETENESS, TIMELINESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED ON THIS WEB SITE OR ANY THIRD PARTY WEB SITE LINKED TO THIS WEB SITE.
As a registered investment adviser, Westfuller must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisers to adopt policies and procedures to protect the “nonpublic personal information” of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information. Westfuller must also comply with any applicable state laws, rules and regulations.
In addition, our firm’s policy, to the extent applicable, is to comply with the Fair Trade Commission’s FACT Act / Red Flags Rule to require covered entities to develop and maintain an effective client identity theft prevention program.
The purpose of these Reg S-P requirements and privacy policies and procedures is to provide administrative, technical and physical safeguards which assist employees in maintaining the confidentiality of nonpublic personal information collected from the consumers and customers of an investment adviser. All nonpublic information, whether relating to an adviser’s current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality.
For Reg S-P purposes, nonpublic personal information includes nonpublic “personally identifiable financial information” plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Westfuller to clients, and data or analyses derived from such nonpublic personal information.
The Federal Trade Commission’s FACT Act / Red Flags Rule became effective December 31, 2010. Current interpretations would include investment advisers which charge advisory fees in arrears as being subject to the rule. The FACT Act / Red Flags Rule requires covered entities to develop and maintain written identity theft prevention programs.
The Compliance Officer is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Westfuller’s client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations. The Compliance Officer may recommend to the President any disciplinary or other action as appropriate. The Compliance Officer is also responsible for distributing these policies and procedures to employees and conducting appropriate employee training to ensure employee adherence to these policies and procedures.
Westfuller has adopted various procedures to implement the firm’s policy and reviews to monitor and ensure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:
Westfuller maintains safeguards to comply with federal and state standards to guard each client’s nonpublic personal information. Westfuller does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:
Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside Westfuller, including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the client.
Westfuller restricts access to nonpublic personal information to those employees who need to know such information to provide services to our clients.
Any employee who is authorized to have access to nonpublic personal information is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving non-public personal information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.
Safeguarding standards encompass all aspects of Westfuller’s privacy procedures. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that Westfuller may adopt include:
Any employee who is authorized to possess “consumer report information” for a business purpose is required to take reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal. There are several components to establishing ‘reasonable’ measures that are appropriate for the firm:
Some methods of disposal to ensure that the information cannot practicably be read or reconstructed that Westfuller may adopt include: