General Investment Disclosure
General Web Site Disclaimers:
Deschaine & Company is an independent SEC registered investment advisor located in Belleville, Illinois. The firm provides investment management services to pensions, profit sharing, and individuals under a written advisory agreement. Under no circumstances does any information posted on deschaineandcompany.com represent a recommendation to buy or sell a security. The information on this site, and in the firm’s related newsletter, Viewpoint or any of the PDF sources and presentation available on the site are not intended to be, nor does it constitute, investment advice or recommendations. The Deschaine & Company in its role as investment advisor to its clients under agreement may buy and sell securities for its clients before and after any particular article and report and information herein is published discussed on the site or provided for in any written materials related to the site or the firm in its services to clients, with respect to the securities discussed in any article and report posted herein. In no event shall Deschaine & Company be liable to any visitor, guest or third party for any damages of any kind arising out of the use of any content or other material published or available on deschaineandcompany.com, or relating to the use of, or inability to use, of any content, including, without limitation, any investment losses, lost profits, lost opportunity, special, incidental, indirect, consequential or punitive damages. Past performance is a poor indicator of future performance. The information on this site, and in its related newsletters, is not intended to be, nor does it constitute, investment advice or recommendations. The information on this site is in no way guaranteed for completeness, accuracy or in any other way.
Web Privacy Policy Disclosure
Protecting the privacy of our clients is important to us. This notice describes the practices and policies through which we maintain the confidentiality and protect the security of your non-public personal information.
What Information We Collect
In the course of providing services to you, we may collect the following types of "non-public personal information" about you:
- Information we receive from you on applications or other forms, such as your name, address and social security number, the types and amounts of investments and bank account information, and
- Information about your transactions with us as well as other account data.
"Non-public personal information" is non-public information about you that we obtain in connection with providing a financial product or service to you, such as the information described in the above examples.
What Information We Disclose
We do not disclose non-public personal information about you or any of our former clients to anyone, except as required by law. In the normal course of serving clients, information we collect may be shared with companies that perform various services such as transfer agents, custodians and broker-dealers. These companies will use this information only for the services for which we hired them and as allowed by applicable law.
Confidentiality and Security Procedures
To protect your personal information, we permit access only by authorized employees. We maintain physical, electronic and procedural safeguards that comply with federal standards to protect the confidentiality, integrity and security of your non-public personal information.
We will continue to adhere to the privacy policies and practices in this notice even after your account is closed or becomes inactive.
For questions about our policy, please contact Mark J. Deschaine at (618) 397-1002.
Full Privacy Policy
As a registered investment adviser, Deschaine & Company 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. 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 Deschaine & Company to clients, and data or analyses derived from such nonpublic personal information.
Background
The purpose of these 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 by 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.
Responsibility
Mark J. Deschaine is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Deschaine & Company's client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations. Mark J. Deschaine may recommend or take any disciplinary or other action as appropriate. Mark J. Deschaine 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.
Procedure
Deschaine & Company has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which may be summarized as follows:
Non-Disclosure of Client Information
Deschaine & Company maintains safeguards to comply with federal and state standards to guard each client’s nonpublic personal information. Deschaine & Company does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:
- As necessary to provide the service that the client has requested or authorized, or to maintain and service the client’s account;
- As required by regulatory authorities or law enforcement officials who have jurisdiction over Deschaine & Company, or as otherwise required by any applicable law; and
- To the extent reasonably necessary to prevent fraud and unauthorized transactions.
Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside Deschaine & Company, 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.
Security of Client Information
Deschaine & Company 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 nonpublic 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.
Privacy Notices
Deschaine & Company will provide each natural person client with initial notice of the firm’s current policy when the client relationship is established. Deschaine & Company shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If, at any time, Deschaine & Company adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies.
The Compliance Officer, Mark Deschaine is responsible for ensuring that required notices are distributed to the Deschaine & Company's consumers and customers.
