Privacy Policy of David Larson Holmes and the David Holmes Agency
Required by the federal Gramm-Leach-Billey Act and state privacy law (State law will apply if it provides more protection than federal law.)
Here at David Larson Holmes and the David Holmes Agency, we are committed to keeping the non-public personal information (“NPI”) we collect confidential and secure. We want you to understand what information we collect, how we use it, and how we protect your privacy. We value your trust and treat your personal information with respect and in accordance with this Privacy Policy. Our Privacy Policy applies to potential, current and former customers.
How do we protect your privacy?
We need some NPI to determine if you are eligible for our products/services. Once a contract is issued, we typically only seek NPI when someone asks, when more coverage is requested or a claim is submitted. Some examples of what we may collect:
Data you provide on applications or other required documents (including but not limited to name, address, phone number, date of birth, Social Security number,
finances, assets, credit, other personal characteristics, accounts and other insurance coverage, employment, beneficiary, avocation, medical history, and
e-mail addresses.)
To whom do we disclose information?
We may share your NPI when you ask or authorize us to do so. Also, the law allows certain disclosures without your authorization. We may share some or all of your NPI with affiliates or nonaffiliates, as permitted or required by law. Examples of who we may share NPI with:
• Nonaffiliates under contract with us, such as claims, billing and customer service vendors and insurance agents/brokers; affiliates that help us provide
services or audit our operations.
What are your rights?
• You have the right to know what NPI we have collected about you; this does not apply to NPI that relates to an actual or possible claim or civil or criminal
action. You may ask us in writing to correct any NPI you believe is not correct.
• If we wish to disclose your NPI for reasons not allowed by law, we will ask for your written authorization. If you give it to us, you may revoke it at any
time. Revocation is subject to the rights of anyone who acted in reliance of your authorization before it was revoked.
• You have the right to opt-out of – or say no to – having their information shared with certain third parties. This opt-out applies only to information collected by
David Larson Holmes and the David Holmes Agency. Personal information obtained outside this agency may be shared with outside companies, provided you
have not informed them that you do not wish your personal information shared with these outside companies. This Privacy Policy will not apply to your
relationships with other financial service providers, such as insurance companies, financial/investment firms, and banks. Their privacy policies will
govern how they collect, use and disclose personal information that you allow them to access.
• We may change our Privacy Policy from time to time. If we do, we will provide you with all the legal rights you are entitled to. This privacy notice supersedes
all prior notices we may have provided to you.
How do you contact us?
If you wish to opt out of the sharing of information as described above, you may write to us at the following address: David Holmes Agency, PO Box 117, Cross
Plains, TX 76443. Please include your name, complete address and phone number so we may adequately match your information with our database.
Privacy Policy Revised 12/30/2008
Code of Ethics for David Larson Holmes/David Holmes Agency
Clear Christian faith and conduct are essential for God’s continued blessing and our hope for the future. The following rules and procedures identify necessary standards and elements of morality, trust, kindness, politeness, honesty, openness, integrity, respect for others, self-respect and expectancy given and expected.
A. The specifics of the Ten Commandments Ex. 20:3-17(excluding the Sabbath day prohibition which has been superceded) serve as our moral foundation and statement, declaring Whom we serve and ultimately to Whom we are accountable. The fruit of the Spirit Gal 5:22-23 guides us in our conduct and treatment of each other and our clients.
B. In accordance with Section 275.204A-1 of the SEC Rules and Regulations, Investment Company Act of 1940, all employees/access persons under the supervision of David Larson Holmes will be subject to this Code of Ethics. As a condition of employment and continued employment, each employee/access person will be required to sign an acknowledgment of receipt of the Code of Ethics annually or as amended.
C. We will uphold the confidentiality and privacy of our clients’ personal information as specified in our most current Privacy Policy. This includes all fiduciary aspects including but not limited to statements, reports, trades, sales, redemptions and contributions.
D. All employees/access persons must submit quarterly and annually to David Larson Holmes a report of their current securities holdings that includes the following
information:
(1) Holdings reports – must contain (a) title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of share, and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership; (b) the name of any broker, dealer of bank with which the access person maintains an account in which any securities are held for the access person’s direct or indirect benefit; and (c) the date the access person submits the report.
(2) Timing of holdings report – each access person must submit a holdings report (a) no later than 10 days after the person becomes an access person, and the information must be current as of a date no more than 45 days prior to the date the report was submitted; and (b) at least once each 12-month period thereafter on a date selected by David Larson Holmes, and the information must be current as of a date no more than 45 days prior to the date the report was submitted.
(3) Transaction reports – access persons are required to submit to David Larson Holmes quarterly securities transactions reports that meet the following
minimum content requirements: (a) date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved; (b) the nature of the transaction; (c) price of the surety at which the transaction was effected; (d) name of the broker, dealer or bank with or through which the transaction was effected; and (e) the date the access person submits the report.
(4) Timing of transaction reports – each access person must submit a transaction report no later than 30 days after the end of each calendar quarter, which report must cover, at a minimum, all transactions during the quarter.
E. A copy of this Code of Ethics is available upon request to current and prospective clients.
Code of Ethics January 12, 2009 REV. 9/10
Required by the federal Gramm-Leach-Billey Act and state privacy law (State law will apply if it provides more protection than federal law.)
Here at David Larson Holmes and the David Holmes Agency, we are committed to keeping the non-public personal information (“NPI”) we collect confidential and secure. We want you to understand what information we collect, how we use it, and how we protect your privacy. We value your trust and treat your personal information with respect and in accordance with this Privacy Policy. Our Privacy Policy applies to potential, current and former customers.
How do we protect your privacy?
- We restrict access to personal information to our employees, insurers, and service providers for legitimate business purposes to assist in providing products and services to you.
- Anyone outside our home office who performs services for us is required to conform to our privacy standards. They are also prohibited from using your NPI for any other purpose.
- We verify that any person asking for your NPI is entitled to it before we give it.
- We collect your health information only with your written authorization.
- We disclose your NPI only as permitted to determine eligibility for coverage and/or services, to process claims, to prevent fraud, and as authorized by you, or as otherwise permitted or required by law.
- We do not disclose your NPI to others for their own marketing purposes.
- We do not reveal your health, character, personal habits or reputation to anyone for marketing purposes.
- We maintain physical, electronic, and procedural safeguards to protect your personal information.
We need some NPI to determine if you are eligible for our products/services. Once a contract is issued, we typically only seek NPI when someone asks, when more coverage is requested or a claim is submitted. Some examples of what we may collect:
Data you provide on applications or other required documents (including but not limited to name, address, phone number, date of birth, Social Security number,
finances, assets, credit, other personal characteristics, accounts and other insurance coverage, employment, beneficiary, avocation, medical history, and
e-mail addresses.)
- Medical information from hospitals, doctors, laboratories and other companies that
provide information about your past or present health condition obtained with
your authorization. - Information about your insurance policies with us or our affiliates (policy number,
coverage, premium, payment history). - As you have authorized: credit reports from consumer reporting agencies; driving records from the Bureau of Motor Vehicles; medical records from the Medical Information Bureau. (NPI obtained from insurance support organizations may be kept by them and disclosed to others.)
To whom do we disclose information?
We may share your NPI when you ask or authorize us to do so. Also, the law allows certain disclosures without your authorization. We may share some or all of your NPI with affiliates or nonaffiliates, as permitted or required by law. Examples of who we may share NPI with:
• Nonaffiliates under contract with us, such as claims, billing and customer service vendors and insurance agents/brokers; affiliates that help us provide
services or audit our operations.
- A consumer reporting agency to detect or prevent fraud.
- A regulatory, legal or government authority, for a compliance audit or under a subpoena or court order.Affiliates or non affiliates that market our products. The
parties we may share NPI with include life and health insurers, insurance agents, and financial/investment firms. We may share our name, address, product purchased, and policy number for these purposes.
What are your rights?
• You have the right to know what NPI we have collected about you; this does not apply to NPI that relates to an actual or possible claim or civil or criminal
action. You may ask us in writing to correct any NPI you believe is not correct.
• If we wish to disclose your NPI for reasons not allowed by law, we will ask for your written authorization. If you give it to us, you may revoke it at any
time. Revocation is subject to the rights of anyone who acted in reliance of your authorization before it was revoked.
• You have the right to opt-out of – or say no to – having their information shared with certain third parties. This opt-out applies only to information collected by
David Larson Holmes and the David Holmes Agency. Personal information obtained outside this agency may be shared with outside companies, provided you
have not informed them that you do not wish your personal information shared with these outside companies. This Privacy Policy will not apply to your
relationships with other financial service providers, such as insurance companies, financial/investment firms, and banks. Their privacy policies will
govern how they collect, use and disclose personal information that you allow them to access.
• We may change our Privacy Policy from time to time. If we do, we will provide you with all the legal rights you are entitled to. This privacy notice supersedes
all prior notices we may have provided to you.
How do you contact us?
If you wish to opt out of the sharing of information as described above, you may write to us at the following address: David Holmes Agency, PO Box 117, Cross
Plains, TX 76443. Please include your name, complete address and phone number so we may adequately match your information with our database.
Privacy Policy Revised 12/30/2008
Code of Ethics for David Larson Holmes/David Holmes Agency
Clear Christian faith and conduct are essential for God’s continued blessing and our hope for the future. The following rules and procedures identify necessary standards and elements of morality, trust, kindness, politeness, honesty, openness, integrity, respect for others, self-respect and expectancy given and expected.
A. The specifics of the Ten Commandments Ex. 20:3-17(excluding the Sabbath day prohibition which has been superceded) serve as our moral foundation and statement, declaring Whom we serve and ultimately to Whom we are accountable. The fruit of the Spirit Gal 5:22-23 guides us in our conduct and treatment of each other and our clients.
B. In accordance with Section 275.204A-1 of the SEC Rules and Regulations, Investment Company Act of 1940, all employees/access persons under the supervision of David Larson Holmes will be subject to this Code of Ethics. As a condition of employment and continued employment, each employee/access person will be required to sign an acknowledgment of receipt of the Code of Ethics annually or as amended.
C. We will uphold the confidentiality and privacy of our clients’ personal information as specified in our most current Privacy Policy. This includes all fiduciary aspects including but not limited to statements, reports, trades, sales, redemptions and contributions.
D. All employees/access persons must submit quarterly and annually to David Larson Holmes a report of their current securities holdings that includes the following
information:
(1) Holdings reports – must contain (a) title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of share, and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership; (b) the name of any broker, dealer of bank with which the access person maintains an account in which any securities are held for the access person’s direct or indirect benefit; and (c) the date the access person submits the report.
(2) Timing of holdings report – each access person must submit a holdings report (a) no later than 10 days after the person becomes an access person, and the information must be current as of a date no more than 45 days prior to the date the report was submitted; and (b) at least once each 12-month period thereafter on a date selected by David Larson Holmes, and the information must be current as of a date no more than 45 days prior to the date the report was submitted.
(3) Transaction reports – access persons are required to submit to David Larson Holmes quarterly securities transactions reports that meet the following
minimum content requirements: (a) date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved; (b) the nature of the transaction; (c) price of the surety at which the transaction was effected; (d) name of the broker, dealer or bank with or through which the transaction was effected; and (e) the date the access person submits the report.
(4) Timing of transaction reports – each access person must submit a transaction report no later than 30 days after the end of each calendar quarter, which report must cover, at a minimum, all transactions during the quarter.
E. A copy of this Code of Ethics is available upon request to current and prospective clients.
Code of Ethics January 12, 2009 REV. 9/10
