Disclosures & Policies
Web Site Use
The Couture Financial, Inc. website is limited to the dissemination of general information pertaining to its investment advisory services. Accordingly, the publication of the Couture website on the Internet should not be construed by any consumer and/or prospective client as a solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. For information pertaining to the registration status of Couture Financial, please contact the State of Florida’s Office of Financial Regulation at (850) 487-9687. Couture Financial does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Couture Financial’s website or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes and all users thereof should be guided accordingly.
Information about you is collected for purposes of administering your account or accounts with us. We collect information about you for specific business purposes and not for resale or transfer to unaffiliated parties. The information we collect, the source of the information and the purposes it is used for are explained below. If you close your account, or it becomes inactive, Couture Financial, Inc. will adhere to the privacy policies and practices described in this notice.
Nonpublic personal information is collected and retained by Couture Financial, Inc. for purposes of administering your account or accounts with us. It is not furnished to third parties for any purpose other than to administer the account. The information we collect can be summarized as follows:
1. Account Establishment Information. This is information furnished by you on forms creating your account with Couture Financial, Inc. and its affiliated companies. Examples are your name and address, Social Security number and beneficiary designations (if applicable).
2. Account Transaction Information. This information includes information obtained from you and the various entities that comprise the assets in your account. It includes correspondence and phone contacts with us concerning the account, account assets, and our services. If the account was transferred from another financial institution, it may contain records from that institution.
Non-public Information that is Disclosed
All information in your account may be disclosed to any person or entity you have authorized pursuant to your account establishment documents. In addition, information may be disclosed to affiliated or nonaffiliated third parties to further your goals in establishing an account with Couture Financial, Inc. Categories of information that are disclosed are as follows:
1. Identifying Information. Examples of this information include your name, address and Social Security or tax identification number.
2. Transaction Information. Examples include your directives to purchase or sell an asset in your account and the receipt of income to the account or distributions from the account.
Parties to Whom We May Disclose Non-public Information
Couture Financial, Inc. may disclose both identification and transaction information to affiliated and nonaffiliated parties for the following reasons:
1. Financial Services Providers. Examples are brokers, transfer agents, mutual fund companies or other representatives of the seller or purchaser of the asset or a firm that provides valuations for securities.
2. Non-Financial Companies. Examples are companies that mail reports to you, statement printers, and tax form providers.
Couture Financial, Inc. does not disclose nonpublic personal information about our clients to any party, except as permitted by law.
How Couture Financial, Inc. Protects the Confidentiality of Your Non-public Information
Couture Financial, Inc. and its affiliates value the trust you place in us. To maintain that trust, we have put into place safeguards to protect the privacy of your nonpublic personal information. We do not sell or trade your information with nonaffiliated companies. When information is provided to third party providers to service the account, safeguards are in place to make certain that the information is used only for the purpose it is provided.
Internally, Couture Financial, Inc. maintains its records on secured computers. Prospective employees are screened for criminal convictions and drug use. Once hired, employees are advised of Couture Financial, Inc. Privacy Policies and of the confidential nature of the information they handle. Employees are limited to accessing only that customer information that is necessary to perform their job functions.
Code of Ethics
“Supervised person” means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser.
“Investment Advisor Representative” (“IA Rep”) is a supervised person who provides investment advice on behalf of the firm. The IA Rep may solicit, meet with, or otherwise communicate with clients about investment advice.
“Access person” is a supervised person who has access to nonpublic information regarding clients’ purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are nonpublic. Access persons include directors, officers, portfolio management personnel, client service representatives who communicate investment advice to clients, and all administrative staff.
Compliance with Federal Securities Laws
This Code of Ethics is based on ethical conduct premised on fundamental principals of openness, integrity, honesty, and trust.
Access persons must comply with the federal securities laws.
Couture Financial, Inc. challenges you to live up not only to the letter of the law, but also to the spirit of the law, as well as the ideals of this firm.
Protection of Material Nonpublic Information
Information about Couture Financial, Inc.’s securities recommendations, and client securities holdings and transactions is material nonpublic information. Couture Financial, Inc. has a duty of care to safeguard this sensitive information. Access persons are to treat this information as confidential.
Our clients and associates entrust CFI with important information relating to their lives and businesses. The nature of this relationship requires maintenance of confidentiality. In safeguarding the information received, CFI earns the respect and further trust of our clients and associates.
Your employment with CFI assumes an obligation to maintain confidentiality, even after you leave the employment of our company.
Any violation of confidentiality seriously injures CFI’s reputation and effectiveness. Therefore, please do not discuss CFI business with anyone who does not work for us (including spouses and close family/friends), and never discuss business transactions with anyone who does not have a direct association with the transaction. Even casual remarks can be misinterpreted and repeated, so develop the personal discipline necessary to maintain confidentiality. If you hear, see or become aware of anyone else breaking this trust, consider what they might do with information they get from you.
If you are questioned by someone outside CFI or your department and you are concerned about the appropriateness of giving them certain information, remember that you are not required to answer, and that we do not wish you to do so. Instead, as politely as possible, refer the request to your manager.
No one is permitted to remove or make copies of any CFI records, reports, or documents without prior approval by your supervisor. Because of its seriousness, disclosure of confidential information could lead to dismissal and may place you in a position of being on the wrong end of legal or criminal action. Your signature at the end of this document signifies acceptance of this responsibility.
Personal Securities Trading Policy
At times, Couture Financial, Inc. and/or its access persons may take positions in the same securities as clients, and we will try to avoid conflicts with clients. The Advisor and its access persons will generally be "last in" and "last out" for the trading day when trading occurs in close proximity to client trades. We will not violate the Advisor's fiduciary responsibilities to our clients. Scalping (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the time of trading.
More detailed Personal Securities Trading procedures are maintained in the CFI Compliance Manual (WSP).
Educating Employees about the Code of Ethics
All existing employees (access persons) obtained a copy of this Code of Ethics upon its initial adoption.
All new employees will obtain a copy of this Code of Ethics.
Amendments to the Code of Ethics will be distributed as/when updated.
Any questions about this Code of Ethics may be directed to the Chief Compliance Officer.