Collection of Information
Stanwich Advisors may collect personal information about investors from the following sources:
- Investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information may include name, address, employment information and financial and investment qualifications as applicable;
- Information about investors from financial institutions and service providers with whom an investor may have authorized to provide such information to Stanwich; and
- Verification services and consumer reporting agencies, including an investor's creditworthiness or credit history, as applicable
Disclosure of Nonpublic Personal Information
Stanwich Advisors does not disclose nonpublic personal information about investors or potential investors to affiliates or nonaffiliated third parties except as permitted by law. For example, Stanwich Advisors may share nonpublic personal information about investors, without the investor's consent, with affiliated and nonaffiliated parties in the following situations, among others:
- in connection with the administration and operations of Stanwich Advisors and other of Stanwich Advisors' products and services, with Stanwich Advisors custodians, attorneys, accountants, auditors, administrators or other service providers;
- to respond to a subpoena or court order, judicial process or regulatory inquiry;
- in connection with a proposed or actual sale, merger or transfer of all or a portion of its business;
- to protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
- to respond to requests for information regarding compliance with anti-money laundering laws;
- upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor; and,
- to assist Stanwich Advisors in offering affiliated products and services to investors.
As indicated above, the foregoing may include responses to inquiries for purposes of compliance with anti-money laundering and ant-terrorist due diligence, disclosure or reporting requirements. Stanwich Advisors also may share nonpublic personal information about investors at investor direction or with investor consent.
Former and Prospective Investors
Protection of Subscriber Information
Stanwich Advisors maintains physical, electronic and procedural safeguards that comply with federal standards to protect investor information. Stanwich Advisors restricts access to the personal information of investors to those registrants and employees who need to know that information in the course of their job responsibilities. When disposing of records containing investor information our registrants and employees are training to use an electronic shredder.
Business Continuity Planning Disclosure FINRA Rule 4370(e)
Stanwich Advisors, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. 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 203-406-1099 or email@example.com, you should call our alternative number 203-249-5939. If you cannot access us through either of those means, you should contact the entities that you have invested in directly for instructions on how you may access investment information, invest additional funds and or provide you with prompt access to funds and securities.
Our Business Continuity Plan
We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records and providing information to our investor's/fund managers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with investors, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact and regulatory reporting; and assuring our investor's/fund managers prompt access to their investments if we are unable to continue our business.
Since you invest directly, the entities that you have invested in are responsible for those records they maintain on your behalf. Additionally, when you invest with our assistance, we take steps to assure that you have paper or electronic copies of everything that you have signed and or obligated yourself to, which results in your having access to essentially the same records as the firm, should you be unable to contact us during an emergency situation. Finally, while most transactions done through us are not time sensitive, every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption. Thus, while each entity with which you have invested desires to restore its own operations and be able to complete existing transactions and accept new transactions and payments within a short period of time, your information 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 2 business days. 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 business within 5 business days. In either situation, we plan to continue in business, and notify you through our emergency number, (203) 249-5939 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 investor's/fund managers prompt interface with the respective companies and entities that have provided investment products to you, through us.
For More Information
If you have questions about our business continuity planning, you can contact us at Stanwich Advisors, LLC, 10 Frost Rd, Greenwich, CT 06830. If you would like to receive a copy of our plan please send a written request to Stanwich Advisors, LLC, Technology Dept., 10 Frost Rd., Greenwich, CT 06830. This plan is subject to modification and investors/fund managers may obtain an updated summary by requesting a written copy by mail. (revised 1/16)
During times of local or national emergencies, the office may be closed and every attempt to return to normal business operation will be made. Our Business Continuity Plan addresses varying degrees of business disruption. To the extent feasible telephone calls to the office's main telephone number will be individually forwarded to a remote location for handling. To contact us, please dial 203-406-1099 or check our website for alternative access information. Our Business Continuity Plan is subject to modification, and any updates may be posted on our website. If an investor or general partner would like to receive a copy of our plan please send a written request to Stanwich Advisors, LLC, 10 Frost Rd. Greenwich, CT 06830, Attention: Compliance Department.
Investor Identification Program
Important Information About Procedures for Establishing a Relationship with our firm: To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each investor in private funds. What this means for you: When you establish a relationship with the firm, we will ask for your name, address, date of birth or tax ID and other information that will allow us to identify you. We may also ask to see your driver's license or passport for individuals and other identifying documents for institutions.
FINRA BrokerCheck allows investors to learn about the professional background, business practices, and conduct of FINRA member firms or their brokers. The telephone number of the FINRA BrokerCheck is 800-289-9999, the website address http://www.finra.org. An investor brochure is also available upon request.
Complaints regarding your relationship with the firm may be directed to Stanwich Advisors, LLC, 10 Frost Rd., Greenwich, CT 06830, 203-406-1099, Attention: Compliance Department.
FINRA Rule 2261
The Statement of Financial Condition is available to the firm's investors. If you would like to request a copy please do so in writing and contact Stanwich Advisors, LLC, 10 Frost Rd., Greenwich, CT 06830, 203-406-1099 Attention: Compliance Department. (revised 1/16)