Background As a registered investment adviser, Fisher Investments (FI) must comply with SEC Regulation S-P, 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. FI has adopted the requirements and target objectives set forth in this Consumer and Customer Information Privacy Policy Statement and Compliance Procedures (“Privacy Policies and Procedures”), which govern the activities of each officer, director, trustee and employee of FI. Federal law requires the following:
To ensure that privacy disclosure laws are not violated, FI has adopted the requirement and target objectives set forth in these Privacy Policies and Procedures. These requirements and target objectives are intended to describe FI's policies, educate employees about related issues and FI's policies, establish procedures for complying with these policies, and monitor compliance with these policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality. Examples could include basic information such as age and telephone number as well as other identifying information about the customer. Glossary
Requirement No confidential information, whatever the source, regarding any FI customer, may be disclosed except as follows:
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