Collection and Use of Client Information
AMG Funds LLC and its affiliated businesses, AMG Distributors, Inc. and The AMG Funds Complex, (collectively, "AMG Funds" or "We") collect only relevant information about our clients that the law allows or requires us to have in order to conduct our business and properly service our accounts. We collect financial and other nonpublic personal information about our clients from the following sources:
- Directly provided by our clients from investment management contracts and other forms; and
- Information provided to us by authorized parties acting on behalf of our clients such as accountants, attorneys and investment consultants.
Keeping Information Secure
AMG Funds maintains physical, electronic and procedural safeguards and procedures to protect your financial and other nonpublic personal information, and AMG Funds continuously strives to improve these safeguards and procedures.
Limiting Access to Information
All of AMG Funds' employees are aware of the importance of maintaining and respecting customer privacy and of the importance of confidentiality. Violations of AMG Funds' privacy policies may result in disciplinary action.
Accuracy of Information
AMG Funds strives to keep accurate client information records, and AMG Funds takes steps to correct errors as they are found. If there are any inaccuracies in your account statements or in any other communications from AMG Funds, please contact us immediately and the necessary corrections will be made.
Use of Personal and Financial Information by Us and Third Parties
Information about AMG Funds' clients that is in the firm's possession is shared with non-affiliated third parties only to the extent necessary for AMG Funds to provide the services for which our clients have hired us, and then only to the extent permitted by law.
AMG Funds typically does not share nonpublic client information with unaffiliated third parties other than as necessary to carry out the actual performance of the investment management services it has been hired to provide. Thus, for example, AMG Funds will share nonpublic client information with brokers and custodian banks in order to buy and sell securities and record those purchases and sales accurately.
AMG Funds may also use such information in the account intake process, which typically includes conducting anti-money laundering screening. As a general rule, AMG Funds does not engage in joint marketing arrangements with unaffiliated third parties that involve the sharing of nonpublic information regarding AMG Funds' clients, nor does it sell client information to unaffiliated third parties for their own marketing purposes. Any exceptions to these practices are made only with the permission of the particular client for the sharing of information with identified third parties or as otherwise required by law.
As an affiliate of Affiliated Managers Group, Inc. (AMG), AMG Funds also shares with AMG (and certain authorized AMG Affiliates, as applicable) information about AMG Funds' experiences or transactions with customers or their accounts. AMG and the AMG Affiliates abide by a "No Share" policy whereby this information is not shared with unaffiliated third parties. In certain situations where information is being shared with an AMG Affiliate, AMG Funds has either a "Limited Authorization Form" in place or confidentiality agreements to cover any access to information and limits the sharing of information to that which is referenced in these agreements.
Maintaining Customer Privacy in Business Relationships
AMG Funds does not share client information with anyone who does not agree to keep such information confidential. If you believe AMG Funds has shared your information inappropriately or if you have questions concerning our policy, please contact AMG Funds' Compliance Department at (203) 299-3500, or write to:
AMG Funds LLC
600 Steamboat Road, Suite 300
Greenwich, CT 06830
Attn: Compliance Department
During the routine course of business, AMG Funds may also obtain nonpublic personal information from persons other than customers. AMG Funds' policy is to protect such nonpublic personal information by employing physical, electronic and information destruction safeguards. AMG Funds limits access to such nonpublic personal information, including social security numbers, to only those individuals who need such information to execute their employment duties or to comply with applicable law or regulation. Any other use, access or distribution of nonpublic personal information obtained by AMG Funds is prohibited.