A. Firm Information 7Twelve Advisors, LLC (“7Twelve” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the
laws of the State of Tennessee. 7Twelve was founded in 2008 and is operated by its President, Andrew D.
Martin. The firm is owned by Andrew D. Martin, Steven J. Eisen and Craig L. Israelson. This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by
7Twelve to institutional clients of the 7Twelve Balanced Portfolio and future public markets investment products.
B. Advisory Services Offered 7Twelve primarily provides investment advisory services to an open-end registered investment management
company, a unit investment trust and other investment advisors (each referred to as a “Client”).
7Twelve Balanced Portfolio
7Twelve provides investment management services to the 7Twelve Balanced Portfolio (the “Fund”), an open-end
registered investment management company. Subject to general supervision by the Board of Trustees of the
Northern Lights Variable Trust (herein the “Board”) and in accordance with the investment objectives, policies
and restrictions of the Fund, the Advisor provides the Fund with ongoing investment management and
administrative oversight. The Advisor has discretion to determine which securities or other investments to
purchase or sell, and what portion of the Fund’s assets will be held in various securities, cash or other investment
instruments, consistent with the Fund’s investment objective and guidelines as set forth in the current
prospectus.
7Twelve seeks to achieve the Fund's investment objective by allocating assets among securities that represent 7
broad asset classes and 12 subcategories using the Advisor's 7Twelve asset allocation model (the "7Twelve
Model™"). The adviser usually does not select individual stocks and bonds, but instead selects exchange-traded
funds ("ETFs") or no load indexed mutual funds that each invests primarily in securities representing one of the
12 subcategories of assets selected under the 7Twelve Model™. The Fund may invest in ETFs that hold
securities from issuers of any market capitalization, credit quality, maturity, country, or trading currency.
However, bond credit quality will be primarily investment grade (that is, rated Baa3 or higher by Moody's
Investors Service, or equivalently rated by another nationally recognized statistical rating organization). The Fund
may also buy ETFs that invest in foreign securities traded on exchanges outside the U.S. and through American
depositary receipts ("ADRs"). Under normal market conditions, the Fund invests at least 65% of its assets in
equity securities (common stocks) and at least 35% of its assets in bonds. For purposes of meeting these
allocations, the Fund defines equity securities to include ETFs that invest primarily in equity securities and
defines bonds to include ETFs that invest primarily in bonds and other fixed income securities.
7Twelve Balanced Portfolio Series
7Twelve provides investment consulting services to the 7Twelve Balanced Portfolio Series (the “Trust”), a unit
investment trust. The Trust is a series trust created by First Trust Portfolios L.P. (the “Sponsor”). Subject to the
investment objectives, policies and restrictions of the Trust, the Advisor provides the Trust with ongoing
investment consultation and administrative oversight. The Advisor provides the Sponsor, in connection with its
sponsorship of the Trust, a list of securities for deposit into the Trust
7Twelve’s investment consultation seeks to achieve the Trust’s investment objective of above-average capital
appreciation. The Trust is a unit investment trust that invests in ETFs that are diversified among multiple asset
classes. Unlike a traditional two-asset 60% equities/40% fixed income portfolio, the Trust invests in seven core
asset groups, which are subdivided into 12 equal asset classes, in an effort to enhance performance and reduce
risk. This investing approach attempts to generate equity-like returns with bond-like risk. Each investment asset
adds an important dimension to the portfolio because of the historically low correlation and behavior between
them. Approximately 65% of the portfolio is invested in equities and diversifying assets and approximately 35% of
the portfolio is invested in fixed income and cash equivalents.
A full description of the services provided by the Advisor for managing the Fund or consulting to the Trust are
available in the current prospectus and statement of additional information (“SAI”) of the Fund or Trust. The
Page 5 prospectus and statement of additional information are available from the SEC website (www.SEC.gov) or by
contacting the Advisor at (615) 341-0712.
Model Management
7Twelve offers Model Management services via Folio Investments, Inc. an internet-based broker-dealer platform
and other institutions ((herein “Platform”). 7Twelve has developed two proprietary models, 7Twelve and 3Twelve
Models (herein “Models”), both of which are managed in accordance to the Model’s investment style and
objective, and are available on the Platform to other investment advisors (“Third-Party Advisors”). The 3Twelve
Total Bond is an equally weighted, passive strategy that invests in each major taxable bond category. The twelve
major asset categories in the global bond universe are the model for the equally-weighted 3Twelve Total Bond
strategy.
7Twelve does not have the authority to buy or sell securities for, or otherwise manage, client account[s] managed
by a Third-Party Advisor utilizing the Platform (“Third-Party Clients”). The Advisor will not be in direct
communication with Third-Party Clients. Any decision to trade, as well as the responsibility for the trade orders,
remains exclusively with the Third-Party Advisor and the Third-Party Client. 7Twelve relies exclusively on Third-
Party Advisors for (i) making suitability decisions, and (ii) for providing “ongoing investment supervisory services,”
based on the needs and circumstances of the Third-Party Clients.
C. Client Account Management 7Twelve Balanced Portfolio Fund
Shares of the Fund are only issued through insurance company intermediaries for variable insurance policies. An
investor cannot invest directly in the Fund. Subscription details are provided in the Fund’s prospectus and other
disclosure documents provided by various insurance companies.
7Twelve Balanced Portfolio Series
Units of the Trust are only issued through the Sponsor. Subscription details are provided in the Trust’s
prospectus and other disclosure documents provided by the Clients selected Custodian.
D. Wrap Fee Programs 7Twelve does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by 7Twelve.
E. Assets Under Management As of December 31, 2019, 7Twelve manages $60,000,000 in discretionary assets, all of which are managed
within the 7Twelve balanced portfolio. Clients may request more current information at any time by contacting the
Advisor.
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A. Fees for Advisory Services 7Twelve Balanced Portfolio Fund
Fees charged to mutual fund clients are set by the Board and shareholders of the Fund and are subject to review
and approval as provided by the Investment Company Act of 1940, as amended (the “1940 Act”). For its investment
management services to the Fund, the Advisor receives an investment management fee calculated as a
percentage of average daily assets of the Fund at an annual rate of 0.15% per annum. Fees are calculated daily
and paid to 7Twelve monthly in arrears. The Fund will incur other operating expenses payable to the Fund’s other
service providers. Fees are negotiated separately on behalf of each series and approved annually at an in-
person meeting of the Boards. The Fund pays the Advisory Fees monthly. The Board must annually approve any
Advisory contract for the Fund. Additional information regarding the fees and expenses of the Fund are detailed
in the Fund’s prospectus.
7Twelve Balanced Portfolio Series
The Sponsor shall cause the Trust to pay to the Advisor $0.02 per Unit calculated and paid one time at the close
of the initial offering period of the Trust. Payment of the fee due to the Advisor with respect to the Trust shall be
made as soon as practicable but no later than 30 calendar days after the end of the Trust’s initial offering period.
Page 6 Model Management Services
7Twelve receives a fixed annual fee of up to 0.50% based on average daily balance, quarter-end, or month-end
market value of assets placed on the Platform within the Advisor’s Models (“Billable Value”).
B. Fee Billing 7Twelve Balanced Portfolio Fund
Investment management fees are accrued daily and paid monthly to the Advisor at the end based on the average
assets during the month. The investment management contract between 7Twelve and the Fund is reviewed
annually for approval by the Board. Additional information regarding the fees and expenses of the Fund are
detailed in the Fund’s prospectus.
7Twelve Balanced Portfolio Series
The Sponsor shall cause the Trust to pay to the Advisor $0.02 per Unit calculated and paid one time at the close
of the initial offering period of the Trust. Payment of the fee due to the Advisor with respect to the Trust shall be
made as soon as practicable but no later than 30 calendar days after the end of the Trust’s initial offering period.
Model Management Services
Model management fees may be payable in advance or in arrears, on a monthly or quarterly basis (“Billing Period”)
and based on the Billable Value of Third-Party Client assets placed on the Platform within the Advisor’s Models.
Fees for the applicable Billing Period are based upon multiplying the Billable Value of the Third-Party Client
accounts by four (for quarterly billing) or twelve (for monthly billing).
C. Other Fees and Expenses Clients may incur additional account fees as shareholders in the Fund or Trust. These fees are described in the
prospectus for the Fund or Trust.
D. Advance Payment of Fees and Termination 7Twelve Balanced Portfolio Fund
7Twelve is compensated for its services at the end of the month after investment advisory services have been
rendered. Clients may redeem their shares in the Fund at net asset value, pursuant to the guidelines set forth in the
Fund’s prospectus and the provisions of the insurance company variable contracts.
7Twelve Balanced Portfolio Series
7Twelve is compensated for its services as soon as practicable but no later than 30 calendar days after the end of
the Trust’s initial offering period. Clients may redeem all or a portion of their Units at any time by sending a
request for redemption to their Custodian through which they hold the Units.
Model Management Services
7Twelve may be compensated for its services either in advance or at the end of the Billing Period. Either party may
terminate the model management agreement with 90 days written notice to the other party. The Advisor will refund
any unearned, prepaid model management fees from the effective date of termination to the end of the Billing
Period. The model management agreement with the Advisor is non-transferable without prior written consent by
both parties.
E. Compensation for Sales of Securities 7Twelve does not buy or sell securities to earn securities commissions and does not receive any compensation for
securities transactions in any Client account, the Fund, or Trust, other than the investment management fees noted
above.
Mr. Andrew Martin is also registered representative of Silver Oak Securities, INC. (“Silver Oak Securities”). Silver
Oak Securities is a registered broker-dealer (CRD No. 46947), member FINRA, SIPC. In his separate capacity as a
registered representative, Mr. Martin will implement securities transactions under Silver Oak Securities and not
through 7Twelve. In such instances, Mr. Martin will receive commission-based compensation in connection with the
purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation
earned by Mr. Martin in his capacity as a registered representative is separate and in addition to the Advisor’s fees.
This practice presents a conflict of interest because Mr. Martin who is a registered representative has an incentive
Page 7 to effect securities transactions for the purpose of generating commissions rather than solely based on the Client.
Clients are not obligated to implement any recommendation provided by the Advisor nor Mr. Martin. Neither the
Advisor nor Mr. Martin will earn ongoing investment advisory fees in connection with any products or services
implemented in the Advisory Person’s separate capacity as a registered representative. Please see Item 10 – Other
Financial Industry Activities and Affiliations.
Mr. Andrew Martin is also licensed as independent insurance professionals. Mr. Martin will earn commission-
based compensation for selling insurance products, including insurance products he sells to Clients. Insurance
commissions earned by Mr. Martin are separate and in addition to advisory fees. This practice presents a conflict
of interest because persons providing investment advice on behalf of the Advisor who are insurance agents have
an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than
solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase
insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry
Activities and Affiliations.
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7Twelve does not charge performance-based fees for its investment advisory services. The fees charged by
7Twelve are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client.
As noted above, 7Twelve Advisors, LLC provides investment management services to the 7Twelve Balanced
Portfolio, an open-end registered investment management company, and the 7Twelve Balanced Portfolio Series,
a unit investment trust. Clients should refer to the offering documents for details on the performance allocation.
The fund or trust manager does not receive a performance allocation from either the 7Twelve Balanced Portfolio
or the 7Twelve Balanced Portfolio Series.
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7Twelve primarily provides investment advisory services to the Fund, Trust and other investment advisors. The
minimum initial investment and the minimum subsequent investment is detailed in the prospectus of the Fund or
Trust.
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A. Methods of Analysis 7Twelve primarily employs fundamental analysis methods in developing investment strategies for its Clients.
Research and analysis from 7Twelve are derived from numerous sources, including financial media companies,
third-party research materials, Internet sources, and review of company activities, including annual reports,
prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity
being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a
potential investment, it does not guarantee that the investment will increase in value. Assets meeting the
investment criteria utilized in the fundamental analysis may lose value and may have negative investment
performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations
are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of
Accounts.
As noted in Item 4 above, the 7Twelve Portfolio consists of twelve (12) equally weighted investments
representing seven (7) asset classes. The Advisor selects the underlying index-based investments based on its
internal due diligence processes.
Page 8 B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. More information about the investment policies and risks of the Fund or Trust can be found in their respective prospectus.
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There are no legal, regulatory or disciplinary events involving 7Twelve or its owner. 7Twelve and its
Advisory Persons value the trust Clients place in the Advisor. The Advisor encourages all Clients to perform the
requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the
Advisor and its Advisor Persons are available on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 149849.
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Investment Adviser Representative and Broker-Dealer Affiliation
As noted in Item 5, Mr. Martin is also a registered representative of Silver Oak Securities. Additionally, Mr. Martin
is an investment adviser representative of Silver Oak Securities. In his separate capacity as a registered
representative, Mr. Martin will receive commissions for the implementation of recommendations for
commissionable transactions. In his separate capacity as an investment adviser representative, Mr. Martin will
typically provide investment management services to retail clients. Clients are not obligated to implement any
recommendation provided by Mr. Martin. Neither 7Twelve nor Mr. Martin, as an IAR of 7Twelve, will earn
ongoing investment advisory fees in connection with any services implemented in Mr. Martin’s separate capacity
as an investment adviser representative and a registered representative. Shareholders of the fund are not
solicited for the services provided by Mr. Martin as a registered representative and investment advisor
representative.
Insurance Agency Affiliations
As noted in Item 5, Mr. Martin is also a licensed insurance professional. Implementations of insurance
recommendations are separate and apart from his role with 7Twelve. As an insurance professional, Mr. Martin
will receive customary commissions and other related revenues from the various insurance companies whose
products are sold. Mr. Martin is not required to offer the products of any particular insurance company.
Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict
of interest in recommending certain products of the insurance companies. Clients are under no obligation to
implement any recommendations made by Mr. Martin or the Advisor.
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A. Code of Ethics 7Twelve has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with 7Twelve (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. 7Twelve and its personnel owe a duty of loyalty, fairness and good faith towards each Client. It is the
obligation of 7Twelve Supervised Persons to adhere not only to the specific provisions of the Code, but also to
the general principles that guide the Code. The Code covers a range of topics that address employee ethics and
conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at (615) 341-0712 or via
email at
[email protected].
Page 9 B. Personal Trading with Material Interest 7Twelve allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. 7Twelve does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. 7Twelve may have an interest
or position in certain securities, which may also be recommended to you.
C. Personal Trading in Same Securities as Clients 7Twelve allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must disclose to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by 7Twelve requiring reporting of personal securities trades by its Supervised Persons for review by the
Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to
detect the misuse of material, non-public information. The Advisor may have an interest or position in certain
securities, which may also be recommended to you.
D. Personal Trading at Same Time as Client While 7Twelve allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward.
At no time will 7Twelve, or any Supervised Person of 7Twelve, transact in any security to the detriment of any Client.
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A. Recommendation of Custodian[s] 7Twelve serves as the Advisor to the Fund pursuant to the advisory agreement approved by the Board, and
investment consultant to the Trust pursuant to the consultant agreement approved by First Trust. 7Twelve is
responsible for buying and selling securities on behalf of the Fund determining the amount of securities to be
bought and sold, which broker-dealers to utilize, and negotiate commissions to be paid. Broker-dealers are
selected if they have the capability to execute transactions on behalf of the Fund using its best efforts to seek the
best overall terms available. All factors are considered in the selection process including but not limited to, the
breadth of the market in the security, the price of the security, the financial condition and execution capability of
the broker-dealer, anonymity and confidentiality, promptness, the quality of any research provided, the net results
of specific transactions, the difficulty in the execution, the size of the order, the operational facilities of the broker-
dealer, the broker-dealer's risk, and the reasonableness of commissions. As noted in Item 4, the Advisor
provides the Trust’s Sponsor, a list of securities for deposit into the Trust.
Following are additional details regarding the brokerage practices of the Advisor for the Fund:
1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. 7Twelve does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – 7Twelve does not receive any compensation from any third party in connection with
the recommendation for establishing a brokerage account.
3. Directed Brokerage – Brokerage relationships are established by the Advisor and reported to the Fund’s
Board.
Page 10 B. Aggregating and Allocating Trades 7Twelve retains a fiduciary obligation to manage Models fairly and equitably and so must ensure that 7Twelve
does not “front run” the Model or self-deal with respect to any securities in such accounts on the Platform. If any
change in the Models result in purchases or sales of securities for the Model at a time when 7Twelve may
engage in transactions for the Fund, the Manager shall provide notice of such change to the Platform in a trading
rotation with the Fund, with the Model occupying a place in such rotation as if the Model were a directed
brokerage account managed by 7Twelve that does not allow step outs. As a result of this rotation, the Model may
trade after the Fund and Trust and may receive less favorable execution.
Investment management and trading practices of the Fund are performed by the Advisor. Additional information
is contained in the prospectus and SAI of the Fund.
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A. Frequency of Reviews Investments in the Fund are monitored on a regular and continuous basis by Mr. Martin, President of 7Twelve.
Formal reviews are generally conducted at least annually or more frequently depending on the needs of the
Client. Reviews for consulting engagements will vary depending on the terms of the agreement and the nature of
the services to be provided.
B. Causes for Reviews Additional information is contained in the prospectus and SAI of the Fund or Trust.
C. Review Reports At any time, a shareholder may receive general information regarding the Fund by calling (877) 525-0712.
Additionally, shareholders may check their Fund account balances by reviewing the statements they receive from
their respective insurance company. Shareholders for the Trust may review statements provided to them from
the brokerage account where their shares are held. 7Twelve has no access to individual shareholder values for
either the Fund or the Trust.
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A. Compensation Received by 7Twelve 7Twelve does not receive any additional compensation.
B. Client Referrals from Solicitors 7Twelve does not engage paid solicitors for Client referrals.
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7Twelve does not accept or maintain custody of any Client accounts. All Clients must place their assets with a
“qualified custodian”. The custodian for the Fund is determined by the Board. The custodian for the Trust is
determined by the Sponsor. For more information about custodians and brokerage practices, see Item 12 –
Brokerage Practices.
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7Twelve generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by
7Twelve. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable
Page 11 limitations to such authority. All discretionary trades made by 7Twelve will be in accordance with each Client's
investment objectives and goals.
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7Twelve will vote proxies on behalf of the Fund based on the proxy voting guidelines approved by the Board and
will report the voting record of the Fund to the Board. 7Twelve will not vote proxies for the Trust. Instead, the
trustee holds the securities on behalf of the unit holders and votes the proxies.
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Neither 7Twelve, nor its management have any adverse financial situations that would reasonably impair the
ability of 7Twelve to meet all obligations to its Clients. Neither 7Twelve, nor any of its advisory persons, have
been subject to a bankruptcy or financial compromise. 7Twelve is not required to deliver a balance sheet along
with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed
six months or more in advance.
Page 12 Privacy Policy Effective: March 12, 2020
Our Commitment to You 7Twelve Advisors, LLC (“7Twelve” or the “Advisor”) is committed to safeguarding the use of personal information
of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here
in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. 7Twelve (also referred to as "we",
"our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
7Twelve does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management
of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you? Driver’s license number Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s] Income and expenses
E-mail address[es] Investment activity
Account information (including other institutions) Investment experience and goals
What Information do we collect from other sources? Custody, brokerage and advisory agreements Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability
documents
Transactional information with us or others Other information needed to service account
How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
Page 13 How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing Do we share? Can you limit? Servicing our Clients We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
7Twelve shares Client information with Silver Oak Securities. This sharing
is due to the oversight Silver Oak Securities has over certain Supervised
Persons of the Advisor. You may also contact us at any time for a copy of
the Silver Oak Securities Privacy Policy.
Yes No
Marketing Purposes 7Twelve does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where 7Twelve or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for marketing purposes. No Not Shared
Authorized Users Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Yes Yes
Information About Former Clients 7Twelve does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
No Not Shared
Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (615) 341-0712 or via email at
[email protected].
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