Hughes Capital Management, Inc. (HCM) is a registered investment adviser with the Securities and Exchange Commission (SEC) under the Investment Adviser Act of 1940.  While the firm has implemented policies and safeguards to abide by the proposed Regulation S-P, as institutional money managers, we are exempt from this rule. However, as fiduciaries, we are obliged to protect the confidentiality and security of our clients’ information – nonpublic identifiable information – with accordance with this Privacy Policy.

 

Our Privacy Policy is as follows:

 

We do not share nonpublic information with outside companies, unless requested by our clients.

 

We may collect nonpublic information about you from the following:

 

Information is retained on individuals who are institutional representatives to HCM, such as decision-makers, administrators, and staff advisors as well as third party pension consultant contact data. None of this information is personal financial information, rather normal business-to-business customer relationship management information.

 

Information derived from a financial service that is specific to an institutional client is available only to that client and its designees.

 

We do not disclose any nonpublic information about our clients and/or sub-advisors to anyone, except as permitted by Law;

 

We may disclose our client list to the public, including the type of service HCM renders, length of the client relationship and the assets under management for marketing purposes only; we never disclose client contact information to third parties;

 

We maintain physical, electronic, and procedural safeguards to protect information we obtain about our clients;

 

We require that all employees adhere to our Privacy Policy standards.