All fiduciary services, including trust and estate administration, are provided by Pendleton Square Trust Company, LLC, a state-charted independent trust company regulated by the Tennessee Department of Financial Institutions.
The Pendleton Square companies, including Pendleton Square Trust Company, LLC, and Pendleton Square Family Office, LLC, do not manage or custody marketable securities. Pendleton Square also does not provide tax or legal advice, and we ask that you consult your tax advisor or attorney for such guidance.
Customer Information Program (CIP) Disclosure
To help the United States Government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person who applies for an account. PSTC must form a “reasonable belief” that the true identity of the customer has been obtained; otherwise, the account will not be opened. This will include providing us with a copy of a government-issued identification, such as a driver’s license or passport.
At Pendleton Square Trust and Family Office, we value and respect customer privacy, and set forth below is our policy concerning the collection and disclosure of customer personal and financial information.
Information We Collect
In providing trust and estate administration or family office services, we may collect personal and financial information from clients including grantors, settlors and beneficiaries. We collect this information in order to provide the highest level of customer service, and in order to fulfill our legal and regulatory responsibilities in administering an account. Information collected may include names, addresses, financial account information, and social security numbers.
Access to Information
It is Pendleton Square’s policy that customer information is highly confidential and will be used only to service an account or to comply with our reporting and oversight responsibilities. We maintain physical, electronic, and procedural safeguards for nonpublic personal information. Access to accounts is limited to those employees or service providers with a need to access that account.
Use and Disclosure of Information
Pendleton Square may use customer information in order to provide services for an account, to improve those services, to implement security measures, and to fight fraud. We will never sell customer information to any party. In the normal course of business, Pendleton Square may share customer information with an outside custodian, securities broker, investment advisor, auditor, accountant, attorney or other third party for the purpose of administering your account. Because we do not disclose any customer information to third parties beyond the necessary disclosures permitted by law, we do not have an Opt Out provision from our privacy notice.
Customers should not email confidential information such as their account number or social security number to Pendleton Square unless they are certain their email is encrypted. Pendleton Square will never email out this information except by encrypted email.
On occasion, Pendleton Square may be required to provide customer information, including account transactions, to governmental agencies and similar bodies in order to fulfill legal and regulatory requirements. Pendleton Square may also be required to disclose information pursuant to a subpoena or court order in judicial proceedings. Pendleton Square will disclose customer information in these circumstances only to the extent required to do so.
If you end your relationship with us, we will continue to adhere to the privacy policies and practices described in this notice.