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DISCLOSURES

ORDER ROUTING DISCLOSURES:   PERSHING LLC   |   NATIONAL FINANCIAL   |   SEC RULE 606

Geneos Wealth Management  - Privacy Policy

Geneos Wealth Management, Inc. ("GWM") values you as a customer and respects your right to privacy. We recognize that you have placed your trust in us, and we take the responsibility to preserve that trust. One way we endeavor to keep your trust is to properly handle that personal information. We pledge to you that:

  • Protection of your privacy is a top priority;
  • Your account information and all documents you provide to us are protected in a secure environment;
  • We only collect personal information in order to accomplish our customer commitments to you;
  • Information about you is only used and shared in limited and controlled ways; and,
  • In the event that we wish to share information about you with non-affiliated third parties, you will be given options concerning what information may be shared, and your privacy wishes will be respected. You may also choose to opt out of any information sharing.

GWM maintains physical, electronic and procedural safeguards to ensure that personal information we have about you is treated responsibly, and in accordance with our privacy policy. We restrict access to information about you only to those representatives and employees who need to know that information in order to provide products and services to you or to conduct GWM's business. Representatives or employees who have access to the information may only use it for legitimate business purposes. In addition, we take steps to safeguard information about you in accordance with applicable data security regulations.

We collect personal information about you from these sources:

  • GWM's Customer Account Form, applications for the purchase of various products, and other forms;
  • Product vendors, as a result of your transactions with us; and/or,
  • Depending on the product you are requesting to purchase, information received from consumer reporting agencies, medical providers or others.

We collect the following types of personal information:

  • Contact information and other personal identifies, such as name, postal address, email address, phone number, social security number or tax identification number.
  • Demographic and family information, such as date of birth, marital status, dependents, beneficiaries, citizenship and information about related parties to an account.
  • Financial, professional and educational information such as investment objectives & experience, assets, income, expenses, net worth, tax status, holdings, transaction history, employment information and background.

We use personal information for the following purposes:

  • Assisting in Identifying you as our customer or our former customer
  • Offering and providing products and services, including opening accounts, communicating with you, providing investment recommendations, and making suitability determinations;
  • Complying with applicable regulatory and legal require (for example, client identification program and know your customer requirements)

We may disclose the following categories of information to entities that perform administrative services on our behalf or as required or permitted by law for legal, regulatory, or other purposes:

  • Information you provide directly to us on the Customer Account Form, applications or other forms;
  • Information we receive about your transactions with us or with our product providers; and/or,
  • If required for the products you purchase, information received from other agencies such as: consumer reporting agencies concerning your creditworthiness, motor vehicle and driver's license reports, medical and employment information, and loss reports.

We may disclose information about you to:

  • Our staff, affiliates, representatives, their affiliated businesses, and third parties who provide you with financial products and services.
  • Nonaffiliated third parties which may include retirement plan sponsors or third-party administrators, mutual fund companies, insurance companies and agencies, other broker-dealers, and clearing firms.

Our privacy policy is the same for current, as well as former clients. If you close your account, in the process of transferring your investments we may share your information with the new broker-dealer or custodian that you or your representative selects. If our representative servicing your account leaves us to join another broker-dealer, the representative is permitted to retain copies of your information so that he or she can continue to serve you at the new firm. The representative is still required to keep your personal information confidential and may only use it to service your account. If you wish to opt out of having your Representative take your personal information upon leaving Geneos, please send a written request to:

Geneos Wealth Management, Inc.
Attention: Compliance Department
9055 E Mineral Circle, Suite 200
Centennial, CO 80112

A special note about medical or health information: While we might receive medical or health information from you at the time of application for various types of insurance, we do not use it or share it  - internally or externally  - for any purpose other than what is directly related to the administration of your policy, account, or claim, as required or permitted by law, or as you authorize us to do.

California Residents:

The California Consumer Privacy Act (CCPA) provides California residents with rights to receive certain disclosures regarding the collection, use and sharing of “Personal Information” as well as rights to know/access, delete and limit sharing of “Personal Information”. As a financial services organization, much of the information we collect is exempt from the CCPA because it is covered by federal or state privacy laws, such as the Gramm-Leach-Bliley Act.

The CCPA defines Personal Information to mean “information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household.  We do not sell your Personal Information; however, as described in this policy, we do disclose information about you to third parties who provide you with financial products and services.

To the extent that we collect Personal Information that is subject to the CCPA, you have the right to request access to Personal Information we have collected about you in the preceding 12 months, the purposes for which we collected it and the categories of third parties with whom we shared it.  Additionally, you have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you; however, there may be certain exceptions as defined in the CCPA that prevent or limit our ability to comply with your request.

To submit a request to exercise your right to access or delete your Personal Information under the CCPA, please call us at 1-888-812-5043 or submit a written request to us at:

Geneos Wealth Management
Attention Compliance – CCPA request
9055 E Mineral Cir., Ste 200
Centennial, CO 80121

All requests are subject to a verification process.  Request by an authorized agent are subject to additional documentation requirements as described below.

Verification Procedures – In order to process your request to access or delete Personal Information we collect; we must verify your request.  We do this by requesting that you verify personal identifiers, such as your name, address, date of birth, account number that we have previously collected from you.

Requests by Authorized Agent – You may authorize another individual or business to make requests on your behalf.  We require that you provide legal documentation confirming the identity and authority of an authorized agent to act on your behalf.  Such documentation may include but is not limited to, a power of attorney, court documents (letters of testamentary, guardianship documents), or notarized statements.

GWM pledges to work to protect the security of your confidential information.

Revenue Sharing Agreements

Geneos Wealth Management, Inc. offers a wide variety of mutual funds, variable annuities and other securities products to clients. In certain instances, product companies participate in activities that are designed to help facilitate the distribution of their products, such as marketing activities and educational programs, and by offsetting expenses that result from the cost of doing business. In return for assistance in facilitating the activities described above, Geneos may receive additional compensation from product sponsors. None of these additional payments are paid to any registered representative who sells these products. The following product companies currently participate in these programs:

Equitable
FS Investments
Griffin Capital
Icon Capital
Jackson National Life
Lincoln Financial
Prudential Annuities
SEI Investments
Cavanal Hill
Forethought Annuities
Loring Ward
Pacific Life
Transamerica
Toews
Nationwide
Brighthouse
Sammons
Security Benefit
Bluerock

Business Continuity Plan

Geneos provides in writing the Business Continuity Plan disclosure statement to all clients at account opening as part of the new account application documents. Geneos also posts the disclosure statement on our web site. Our plan is subject to modifications at any time and updates will be posted to our website or customers may request an updated summary by written request to Geneos.

In the event of a business disruption, Geneos clients should always contact their Registered Representative first. All Geneos’ Branch Managers have a copy of the full Business Continuity Plan and should be the first point of contact for clients with questions about their accounts.

Geneos has taken significant steps to mitigate business disruptions resulting from a variety of events. We have reviewed our activities to assess each process to determine what is critical and how we can continue to do business with minimal disruption.

Geneos takes step daily to back up all of our information. Additionally, we maintain offsite back-up facilities to storage all of our data in the event of business disruption in our home office.

While our plans attempt to deal with the potential impact of a variety of scenarios, any specific response will be highly dependent upon the nature and extent of the circumstances of the event. Our plan is subject to modifications at any time and updates will be posted to our website or customers may request an updated summary by written request to Geneos.

ScenarioResponseRecovery Time
Firm-OnlyGeneos will continue doing business. Employees will continue operations from their home locations via our VPN.ASAP
Denver Tech-Center OutageGeneos will continue doing business. Employees will continue operations from their home locations via our VPN.ASAP
Regional OutageGeneos will continue doing business through it branches. Branches will be contacted by whatever means is available to Geneos. The Representative / customers should contact Pershing and/or National Financial emergency numbers in order to continue doing business.ASAP

Geneos Sweep Program: Pershing Accounts

The rates for the Insured Deposit Program (“Program”) are set forth below. Interest accrues daily and is paid monthly. Amounts reflecting interest paid will be presented on your brokerage account statements. The rates are subject to change at any time, without notice to you, and will vary.

The Liquid Insured Deposits A Account is a secure savings vehicle that offers FDIC insurance of up to $2,500,000 on your cash deposits1.

LIQUID INSURED DEPOSITS A SWEEP PROGRAM RATES AS OF 05/04/2020

Average Linked Balance2 Interest Rate APY
From To
$0.01 $49,999.99 0.03% 0.03%
$50,000.00 $99,999.99 0.04% 0.04%
$100,000.00 $499,999.99 0.05% 0.05%
$500,000.00 $999,999.99 0.07% 0.07%
$1,000,000.00 and above 0.10% 0.10%

1 Individual deposit account balances over $2.5 million are in excess of the Maximum Applicable FDIC Deposit Insurance Amount and may not be eligible for FDIC insurance coverage.

2 Each account will earn a rate of interest, which may fluctuate daily depending on market conditions. The interest rates on the Deposit Accounts will vary based upon the value of the assets and cash you maintain in your brokerage account, including amounts on deposit in your Deposit Accounts. Pershing will link your brokerage account to additional brokerage accounts you hold at Pershing registered under the same social security number to determine your Interest Rate Tier. The aggregate assts of all “linked” brokerage accounts is referred to as your “Linked Balance.” The APY and interest rate quoted reflects the deduction of the comprehensive fee described in the Terms and Conditions from the interest earned on the FDIC-insured money market account(s) at the Program Bank(s).

Geneos Sweep Program: NFS Accounts

The rates for the Insured Deposit Program (“Program”) are set forth below. Interest accrues daily and is paid monthly. Amounts reflecting interest paid will be presented on your brokerage account statements. The rates are subject to change at any time, without notice to you, and will vary.

The NF Bank Deposit Sweep Program is a secure savings vehicle that offers FDIC insurance of up to $2,500,000 on your cash deposits1.

NF BANK DEPOSIT SWEEP PROGRAM RATES AS OF 04/01/2020

Program Deposit Balance Tier Range2 Interest Rate3 APY
From To
$0.01 $4,999.99 0.01% 0.01%
$5,000.00 $24,999.99 0.01% 0.01%
$25,000.00 $49,999.99 0.01% 0.01%
$50,000.00 $99,999.99 0.01% 0.01%
$100,000.00 $499,999.99 0.01% 0.01%
$500,000.00 and above 0.01% 0.01%

1 Individual deposit account balances over $2.5 million are in excess of the Maximum Applicable FDIC Deposit Insurance Amount and may not be eligible for FDIC insurance coverage.

2 Important Note: Balances will earn the same rate of interest regardless of the Program Bank with which funds are deposited. Interest rate is based upon each account’s Program Deposits in accordance with the above Interest Rate Tiers (described in more detail in the BDSP Disclosure Document). The rate of interest paid is currently evaluated on a daily basis.

3 Interest rates/APY will be determined based on prevailing economic and business conditions. Interest accrues daily and is paid monthly. Amounts reflecting interest paid will be presented on brokerage account statements. Interest rates are subject to change at any time.