USA Patriot Act/ Privacy Policy

Arista Investment Advisors' Client Identification Program is as follows:

Before opening a client “account” or granting trading authority, Arista will collect, at a minimum, the following information from the client, including all signatories and all persons granted authority to effect transactions in an account:

For U.S. persons and entities:
· Client’s name
· Tax Identification Number
· Address
· Date of Birth

For non-U.S. persons and entities:
· Client’s name
· Identification Number – from taxpayer, passport, alien id card or similar photograph-bearing source
· Address
· Date of Birth


Verification
Arista Investment Advisors will verify this information by verifying documents within a reasonable period after establishing the account. Non-document based means of verification will be used as an alternative when documents are not available, or in addition to documents, when concerns appear indicating that accounts and customers may be high risk.

Documents may include un-expired government-issued identification, showing nationality or residence, with a photograph or similar safeguard (i.e. driver’s license). For businesses, verification may be documents showing the entity’s existence (e.g., articles of incorporation).

Non-document methods will be used when document verification is not available or when “red flags” are noted, such as an unwillingness or inability to disclose information relating to identity, occupation, or assets; the use of offshore holding companies; a lack of concern regarding investment objectives/risks or advisory fees; clients from countries identified as money laundering havens; clients who appear to be acting as agents for undisclosed principals; clients who are senior foreign political officials, their immediate family members and their close associates. They may include contacting a client, checking reports from credit bureaus or public databases, and/or obtaining references from other financial institutions.

If the identity of a client cannot be verified within a reasonable period of time by means of documents, but the client is cooperative and forthcoming with non-documentary information and no “red flags” are noted, then an account may still be opened and transactions conducted while identification is being verified. If “red flags” are noted, an account will not be opened and/or no transactions will be conducted until identification is verified. If after a reasonable period of time, all reasonable attempts to verify identification have been made and the client’s identity still cannot be verified, an account will not be opened, and/or Arista will de-link itself from an existing account immediately and a suspicious activity report will be filed.

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PRIVACY POLICY

Our firm is committed to safeguarding the confidential information of our clients. We hold all personal data provided to us in the strictest confidence. Indeed, we require your specific permission before we will discuss your affairs with anyone external to the firm. The information we compile includes that provided by you on our questionnaire, collected from your previous advisors, if any, and from statements and other sources that you give us.

We have never disclosed information to nonaffiliated third parties (such as brokerage firms, credit-card or insurance companies,) except as permitted by law, or in carrying out the duties for which you retained us. We do not anticipate any change to this policy, and, in the unlikely event that we were to change it, we will contact you prior to such a change and give you the option to protect your data.

As you know, we use health and financial information that you give us to assist you in meeting your personal financial goals while guarding against any perceived or real infringements of your privacy rights. Our policy with respect to personal information is as follows:

· We limit access to information to only those employees who have a business or professional reason for knowing it, and only to nonaffiliated parties as permitted or required by law – for example, federal regulations permit us to share a limited amount of information with brokerage firms in order to transact business on your behalf, and federal and state regulators, in the course of inspecting us may also have access to your data.
· We maintain a secure physical office and our computer network is protected by a security firewall to ensure that your information is not placed at unreasonable risk.
· For unaffiliated third parties that require access to your personal information (such as a brokerage firm,) we also require strict confidentiality in our agreements with them and expect them to keep this information private.
· We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
· Disclosure of private client information is an offense subjecting employees to termination.
· We will maintain your files, with your data, as long as you are a client, and for as long thereafter as may be required by law and the CFP Board Code of Ethics and Professional Responsibility. After this required period of retention, all such information will be appropriately destroyed.