Detwiler Fenton Investment Management LLC updates its Form ADV annually. The Form ADV is available to the public at www.adviserinfo.sec.gov. Clients can also obtain a copy by sending an email to email@example.com or by writing to:
Detwiler Fenton Investment Management, LLC
225 Franklin Street, Suite 2600
Boston, MA 02110
The Detwiler Fenton companies (Detwiler Fenton & Co. and Detwiler Fenton Investment Management LLC) have prepared and implemented a Business Continuity Plan ("BCP") in accordance with the FINRA optional guide.
There are 10 critical elements of a BCP specified in FINRA Rule 4370. We have addressed each element and its applicability to our business. There are no elements for which management has not included a specified response. The components to the response include the following sections:
The above-listed 10 elements are not exhaustive. We have addressed other key areas included in this BCP for it to be complete and thorough based on our business and operations.
Our BCP anticipates two kinds of Significant Business Disruptions: Internal Significant Business Disruptions ("ISBDs") and External Significant Business Disruptions ("ESBDs"). ISBDs affect only our ability to communicate and do business, such as a fire in our building or a disruption in electricity or phone services. ESBDs, such as a terrorist attack, a city flood, or a wide-scale regional disruption, prevent the operation of the securities market and may affect the operations of a number of firms. Our response to an ESBD relies heavily on other organizations and systems, primarily on the capabilities of the clearing firm for DFIM, Pershing LLC/ INTL FCStone Securities Inc. ("INTL/Pershing,"), and their BCP execution. Our policy is to respond to a Significant Business Disruption by safeguarding employees' lives and our property, making financial and operational assessments, quickly recovering and resuming operations, protecting all books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.
We maintain backups of critical systems in our Boston office. All mission-critical systems are Internet accessible and any Significant Business Disruption should not disrupt access to such systems through any connection to the Internet. We also clear securities transactions through INTL/Pershing, on behalf of DFIM. They are contractually obligated to maintain a business continuity plan and ensure the capacity to execute that plan. INTL/Pershing, on behalf of DFIM, represents that it backs up our records at a remote, out-of-region site, and operates other back-up operating facilities in a geographically separate area with the capability to conduct the same volume of business as its primary site. INTL/Pershing, on behalf of DFIM, has also confirmed both the effectiveness of its back up arrangements to recover from a wide scale disruption through testing and that it tests these back up arrangements on a regular basis (twice yearly). NFS represents that it will advise us of any material changes to its plan that might affect our ability to maintain our business.
The entire Business Continuity Plan is kept at our Boston office, as well as at every branch office and the private residences of all members of the BCP Committee. A copy of this summary will be sent to all clients upon the opening of a new account. If after a significant business disruption you cannot contact us as you usually do at 800-950-2400, either go to our website at www.detwilerfenton.com or send an e-mail to firstname.lastname@example.org.
Downloading information or software from this site binds the user to agree not to copy it or not to remove or obscure any copyright or other notices or legends contained in any such information.
To help the government fight the funding of terrorism and money laundering activities, and to verify your identity, federal law requires that Detwiler Fenton obtain your name, date of birth, address, and a government issued identification number before opening your account. In certain circumstances, Detwiler Fenton may obtain and verify this information with respect to any person(s) authorized to effect transactions in an account. For certain entities, such as trusts, estates, corporations, partnerships or other organizations, identifying documentation is also required. Your account may be restricted and/or closed if Detwiler Fenton cannot verify this information. Detwiler Fenton will not be responsible for any losses or damages (including, but not limited to, lost opportunities) resulting from any failure by you to provide this information, or from any restriction placed upon, or the closing of, your account.
Pershing, on behalf of DFIM, performs regular mailings of all customer account statements, trade confirmations, margin account notices, and confirmation of changes to customer information (including address, financial objectives, risk tolerance and other account information) to the account address of record. Please pay careful attention to the mailings received from our clearing firm. Such mailings notify you of activity or changes in your account. It is your responsibility to review your account activity and any account changes and inform us immediately if there are errors or inaccuracies contained in the confirmation or statement. Should you find any errors, please contact the Firm immediately at 800-950-2400, send an e-mail to email@example.com or write the Firm at the address above to the attention of the Operations Department. Please note that changes to your address may only be accepted by written request. Changes of address to a PO Box will not be accepted.
The information provided on this site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Detwiler Fenton to any registration requirement within such jurisdiction or country. Neither the information nor any opinion contained in this site constitutes a solicitation or offer by Detwiler Fenton to buy or sell securities, futures, options, or other financial instruments or provide any investment advice or service.
The Detwiler Fenton companies (Detwiler Fenton & Co. and Detwiler Fenton Investment Management LLC) recognize the importance of protecting your privacy. We have policies in place to maintain the confidentiality and security of your personal information.
We collect nonpublic personal information concerning you in the following ways:
We employ physical, electronic, and procedural controls in keeping with industry standards and practices. Your personal and account information is available only to authorized personnel who need this information in order to provide products or services to you.
We do not disclose any non public personal information about you to any other entity, except as required by law. However, we must disclose certain information in order to facilitate transactions on your behalf.
It is not our policy to share non public personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since this sharing is necessary to either service customer accounts or is mandated by law, there are no allowances made for clients to opt out.
If you decide to close your account, we will continue to adhere to the privacy policies and practices as described in this notice.
We do log user IP addresses. IP addresses are saved in the web server's site log and are used for authentication.
Users who leave this site via a link contained herein and view content that is not provided by Detwiler Fenton do so at their own risk. Such linked content will not have been developed, checked for accuracy, or otherwise reviewed by Detwiler Fenton. Detwiler Fenton is not responsible for damages or losses caused by any delays, defects, or omissions that may exist in the services, information, or other content provided in such site, whether actual, alleged, consequential, or punitive. Detwiler Fenton makes no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party including, without limitation, the accuracy, subject matter, quality, or timeliness of any electronic content.
If you have any questions, concerns or complaints, please feel free to contact the Compliance Department at:
800-950-2400 Toll Free
All written correspondence may be directed to:
225 Franklin Street, Suite 2600
Boston, MA 02110