…is to find ways to convey the history and mechanics of the capital markets and the true workings of the investment industry to clients, potential clients and nonclients. The challenging and creative part of this journey comes from the fact many of those individuals have diverse–but nonfinancial–backgrounds. I need to make sure clients understand what they own, how much it costs to own, and how worldwide events will affect those investments. I also need to make sure that the spouses and children of my clients have an understanding of the same items. Lastly, I want to make sure my clients–and myself–sleep well at night. Of the things I aim to deliver, the most valuable one might be the good night’s sleep.
Background and qualification information is available at FINRA’s BrokerCheck website
Securities offered through Trustmont Financial Group, Inc.
Member SIPC/FINRA
Advisory services offered through Trustmont Advisory Group, Inc.
200 Brush Run Road, Greensburg, PA 15601 1-800-618-3666
Ken is licensed in the following states: PA, FL, MD, OH, LA, NC, VA
Item 1: Introduction
Brokerage and advisory service fees differ and it is important for you to understand the differences. Free and simple tools are available to help you research firms and financial professionals at Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.
Item 2: Relationships and Services
What investment services and advice can you provide me?
Depending on your needs and investment objectives, we can provide you with services in a brokerage account, investment advisory account, or both at the same time. You should carefully consider which types of accounts and services are right for you.
Broker-Dealer ServicesBrokerage Accounts | Investment Adviser ServicesAdvisory Accounts |
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Conversation Starters: Given my financial situation, should I choose an investment advisory service? Should I choose a brokerage service? Should I choose both types of services? Why or why not? How will you choose investments to recommend to me? What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?
Broker-Dealer ServicesBrokerage Accounts | Investment Adviser ServicesAdvisory Accounts |
With stocks or exchange-traded funds, this fee is usually a separate commission. With other investments, such as bonds, this fee might be part of the price you pay for the investment (called a “mark-up” or “mark-down”). With mutual funds, this fee (typically called a “load”) reduces the value of your investment.
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The amount paid to our firm and your financial professional generally does not vary based on the type of investments we select on your behalf. Fees are deducted from your account, thereby, reducing the value of your account. For fees charged on an hourly basis or flat rate, you may also have the option to pay your fees by invoice instead of having the fee deducted from your account.
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Conversation Starters: Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?
What are your legal obligations to me when providing recommendations as my broker-dealer or when acting as my investment adviser? How else does your firm make money and what conflict of interest do you have?
Broker-Dealer ServicesBrokerage Accounts | Investment Adviser ServicesAdvisory Accounts |
Our Conflicts:
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Conversation Starters: How might your conflicts of interest affect me, and how will you address them?
Broker-Dealer ServicesBrokerage Accounts | Investment Adviser ServicesAdvisory Accounts |
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Conversation Starters: Who is my primary contact person? Is he/she a representative of an investment advisor or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?
Protecting your privacy is very important to the Trustmont companies. We want you to understand what information we collect and how it is used. We collect and use “nonpublic personal information” in order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible. We treat nonpublic personal information in accordance with our Privacy Policy.
Information We Collect and From Whom We Collect It
We may collect nonpublic personal information about you from the following sources:
•Information we receive from you on applications or other forms;
•Information about your transactions with us, our affiliates, or others;
•Information we receive from you voluntarily, such as your email address and any information contained in your email messages. “Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you. This information may be collected in person, by mail, fax, or by other electronic means as permitted by law or in accordance with express authorization from you. FINRA rules declare that any and all customer information including statements, confirms, new account documents, and correspondence are the property of Trustmont. It is Trustmont’s position that this information also belongs to the registered representative or advisor who introduces the customer to Trustmont. Therefore, should a registered representative or advisor leave Trustmont, he/she will be permitted to take with them their copies of customer information. If you do not agree to this provision as a customer, you are required to notify Trustmont in writing. Your private information will be permitted to go with the registered representative or advisor upon their departure from Trustmont unless your written notice is on file.
What Information We Disclose and to Whom We Disclose It
We do not disclose any nonpublic personal information about you to anyone without your express consent, except as permitted or required by law. We may disclose the nonpublic personal information we collect, as described above, to persons or companies that perform services on our behalf.
Your Right to Verify Accuracy of Information We Collect
Keeping your information accurate and up to date is very important to us. You may access and correct nonpublic personal information about you that we collect except for information relating to or in anticipation of a claim or a criminal or civil proceeding.
Our Security Procedures
We restrict access to the nonpublic personal information about you and allow disclosure only to those employees or persons and companies as permitted by law to assist in providing products or services to you. We maintain physical, electronic, and procedural safeguards to protect the nonpublic personal information about you. Should your relationship with us end, we will maintain and only disclose nonpublic personal information that we have about you in accordance with this Privacy Policy.
Important Information You Need to Know About Opening a New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account. This Notice answers some questions about Trustmont Group’s Customer Identification Program.
What types of information will I need to provide?
When you open an account, Trustmont Group is required to collect information such as the following from you:
●Your name
●Date of birth
●Address
●Identification number:
●U.S. Citizen: taxpayer identification number (social security number or employer identification number)
●Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.
You will also need to show your driver’s license or other identifying documents. A corporation, partnership, trust, or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement. U.S. Department of the Treasury, Securities and Exchange Commission and FINRA rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.
What happens if I don’t provide the information requested or my identity can’t be verified? Trustmont Group may not be able to open an account or carry out transactions for you. If you have already opened an account, they may have to close it. We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.
Securities Investor Protection Corporation (SIPC)
You may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at (202) 371-8300 or by visiting the SIPC website at www.sipc.org.
Trustmont Advisory Group, Inc. does not vote proxies on behalf of its clients.
This Ethics Policy is for all employees, registered representatives and advisors of Trustmont Financial Group, Inc. (TFG) and Trustmont Advisory Group, Inc. (TAG). This policy is a guide to ethical practices in working with clients, the public, correspondents, Mutual Fund and Insurance Companies.
It is TFG’s and TAG’s policy to conduct its business in full compliance with both the letter and the spirit of the securities and other laws and regulations. This policy includes dealing fairly and honestly with all customers, making full disclosures of all material facts in connection with securities transactions, and obtaining sufficient customer information to determine that all securities transactions are suitable for the customer. Each registered representative and advisor has both a legal and business obligation to comply with all applicable laws and regulations. To meet these objectives, each registered representative and advisor should be fully informed and knowledgeable about the securities laws and regulations and must certify his or her understanding of those matters prior to any sales activity, and periodically thereafter, as part of an ongoing compliance program. TFG and TAG fully expect its registered representatives and advisors to exercise the highest degree of professional ethics in all actions they undertake on behalf of the firm(s). In furtherance of that objective, TFG and TAG expect its registered representatives and advisors to act in accordance with the policies set forth herein at all times.
Registered representatives and advisors often learn confidential information about TFG and TAG. As such, company information is confidential and not to be shared with the general public unless specifically approved, in writing, by an officer of the company or the Compliance Department.
Unauthorized use of customer information, whether within or outside TFG or TAG, is a very serious violation and may result in immediate termination. Customer information may not be disclosed to third parties except as authorized for processing customer transactions or implementing customer requests. Registered representatives and advisors may not disclose customer information to anyone outside TFG or TAG unless:
1.The outside firm needs to know the information in order to perform services for TFG or TAG and is bound to maintain its confidentiality.
2.The client has consented, in writing, or been given an opportunity to request that the information be shared.
3.As required by law or self-regulatory organizations.
4.Authorized by the Compliance Department.
Registered representatives and advisors should be mindful of these obligations when using the telephone or electronic mail, especially when using these forms of communications in the public where the conversation may be overheard or read. All documentation containing personal or confidential customer information should be shredded and disposed of properly when no longer needed.
A list of conflicts can not be exhaustive, thus when there is the slightest possibility for conflict, the registered representative or advisor must discuss the situation with an officer or Compliance Department of TFG or TAG and receive written approval prior to proceeding. Also, a registered representative or advisor, without written approval of an officer or Compliance Department;
1.May not give or receive gifts of more than a token value (currently $100.00)that are in any way connected with business relationships.
2.Must comply with all provisions of federal, state and self regulatory agency securities laws as well as all company policies.
Outside business activities must be disclosed, in writing, to the Compliance Department. These include, but are not limited to, being appointed an officer or director of a public or private company, any activity where compensation is received, or the making of a private investment.
Brokerage accounts may be opened with other broker/dealers but must be disclosed to the Compliance Department. Duplicate copies of confirms and statements are to be issued to the company, attention Compliance Department.
No employee shall conduct a transaction in a security while in possession of inside material non-public information concerning that security or entity.
No employee shall enter into a transaction intended to raise, lower, or maintain the price of any security or to create a false appearance of active trading.
The SEC makes reference to “access persons”. An access person is a supervised person who has access to non-public information regarding client’s purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations. Thus, any registered representative or advisor, and any of their office staff, working within their office or outside, are determined to be an access person. TFG and TAG require certain access persons to submit personal securities transaction reports. The required persons would be all registered representatives and advisors licensed with TFG and TAG.
SEC Rule 204A-1(b)(i) requires a complete report of each access person’s securities holdings at the time the person becomes an access person and at least once annually. The Rule requires new advisors to submit their report no later than 10 days after the person becomes an access person, and information must be current as of the date no more than 45 days prior to date the person became an access person. At least once annually the advisor must submit the report to the compliance department and the information must be current up to 45 days prior to the report being submitted.
Additionally, the SEC requires reports of all personal securities transactions by access persons, and the adviser to review those reports, which are due no later than 30 days after the close of the calendar quarter. (SEC Rule 204A-1(b)(2) Two exceptions are permitted under this rule. No reports are required:
1.With respect to transactions effected pursuant to an automatic investment plan.
2.With respect to securities held in accounts over which the access person had no direct or indirect influence or control.
Every Registered Representative/Advisor must provide the Compliance Department copies of all statements from the broker/dealer, mutual fund company, insurance company or any other investment company. The copies must be accompanied with a signed statement attesting to the fact that these copies represent all reportable transactions made for that quarter. Each of those accounts should direct duplicate confirms at the time of the transaction(s) to the Compliance Department.
SEC Rule 204A-1 treats all securities as reportable, with the following exceptions;
1.Transactions and holdings in direct obligations of the US Government.
2.Money market instruments (banker’s acceptances, bank certificates of deposit,commercial paper, re-purchase agreements and other high quality short-term debt instruments.
3.Shares of money markets.
4.Transactions and holdings in shares of other types of mutual funds.
5.Transactions in units of a unit investment trust if the unit investment trust is invested exclusively in unaffiliated mutual funds.
TFG and TAG do not participate in IPO’s.
It will be the responsibility of the Compliance Department to report any violations of the Ethics Policy as required by SEC Rule 204A-1 to the president of TFG and TAG.
All employees will receive a Code of Ethics upon initial employment with Trustmont. Each Registered representative/Advisor must acknowledge annually that they are in receipt of the Code and will comply with the provisions.
Material discussed is meant for general illustration and/or informational purposes only. It is not to be construed as tax, legal, or investment advice. Although the information has been gathered from sources believed to be reliable, please note that individual situations can vary. Therefore, the information should be relied upon when coordinated with individual professional advice.
The views stated in this letter are not necessarily the opinion of Trustmont Financial Group, and should not be construed, directly or indirectly, as an offer to buy or sell any securities mentioned herein. Investors should be aware that there are risks inherent in all investments, such as fluctuations in investment principal. With any investment vehicle, past performance is not a guarantee of future results.
valuekaszak is not affiliated with Trustmont Group