Hooker & Holcombe Investment Advisors, Inc.
Privacy Policy

Hooker & Holcombe Investment Advisors, Inc. (“HHIA”) respects the privacy and confidentiality of all client information. We adhere to the SEC’s (Securities Exchange Commission) privacy rule, Regulation S-P, requiring investment advisers to issue initial and annual privacy notices to all clients. Regulation S-P places an affirmative obligation on advisers to insure the security and confidentiality of client nonpublic personal information, which is defined as personally identifiable financial information obtained in any of the following ways:

• Information supplied by client
• Information resulting from transactions
• Information obtained in providing products or services

HHIA collects nonpublic personal information in the following ways:

• Information we receive from applications for retirement plans such as Employer Identification Number or Tax Identification Number.
  

• Information about transactions on behalf of retirement plans with custodian banks, brokers, mutual fund companies and third party administrators which include account balances, confirmation of transactions and fees paid to certain service providers (if applicable).
  

• Information about participant retirement plan payments such as name, social security number, address, date of birth and payment amount (if applicable).
  

• Information provided by other service providers for plans which may include, employee salaries, date of birth, estimated retirement dates and estimated future benefit payments (if applicable).

HHIA does not disclose nonpublic personal information to non-affiliated third parties except as permitted by our clients or permitted by law. HHIA may disclose nonpublic personal information to its affiliated companies, Hooker & Holcombe, Inc., and Hooker & Holcombe Retirement Services, Inc., to the extent it is necessary to conduct business and provide services on behalf of our clients’ retirement plan(s). Access to information is restricted to only necessary employees. HHIA maintains physical, electronic and procedural safeguards to insure the security of nonpublic personal information.