(Part 2A and 2B of Form ADV)
2390 E Camelback Rd #130
Phoenix, Arizona 85016
1. Various grammatical changes that do not change the meaning of any section.
2. Changed minimum financial planning fee to reflect changing business needs. Minimum Fee raised from $2000 to $4000 at the time of the change no client or prospect had an in force agreement or proposal for $2000.
3. Created a parallel web-accessible version of this document to provide easy access for clients.
4. Added additional URL information.
5. Corrected email and linking in the document.
6. Corrected font and layout issues.
Ability First Financial, LLC. was founded in 2018 to provide expert advising solutions to Individuals, Businesses, and Organizations needing advance tax mitigation and investment strategies.
Ability First Financial, LLC. provides personalized and confidential investment advice to Individuals, Pension and Profit-sharing plans, Trusts, Estates, Charitable Organizations, and Businesses. Advice is provided through consultation to help determine (among other things,) the client’s investment objectives and risk tolerance.
Ability First Financial, LLC. focuses on long-term relationships with businesses and their Executives.
Ability First Financial, LLC. provides investment advice through a variety of third-party investment managers, Mutual Funds, ETFs, REITs, and other alternatives with the client making the final decision on investments. Ability First Financial, LLC. does not act as a custodian of client assets. Client assets are held at third-party trust companies.
Periodic reviews of the client’s investment selection and financial situation are undertaken to address the performance and structure of the investment program as well as assess any changes in the client’s risk tolerance and investment objective. If necessary and agreed upon by the client, specific courses of action may be implemented. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur.
Ability First Financial, LLC operates both as an RIA and an Insurance agency. Ability First is aware of the inherent conflict of interest that this may pose, and discloses it to all clients, and whenever appropriate seeks to find suitable products that do not pay commission.
Ability First Financial, L.L.C. uses the following additional names for marketing and advertising purposes.
Additional names do not in any way change the services or offerings but are used solely for marketing purposes.
To simplify navigation the Prefix “Retire.” has been added to simplify participants access to there accounts.
Seth Aaron Rosenberg, LUTCF, GFS CRD No. 6414032
At the time of filing, no other Access persons exist.
Seth Rosenberg CRD No. 6414032
Ability First Financial, LLC. offers fee-based advice for Financial Planning for Business and Business owners. Financial Planning services are provided on an annual basis for clients that would like a holistic review of all their financial needs and goals. Financial Planning services are distinct from any investment management services and are not performance based. Financial planning services may include specific investment category recommendations, insurance products, tax mitigation, estate planning, and business planning advice. Financial planning agreements generally have a $4000 per year minimum. Planning requires extensive involvement between the advisor and client if the client is unable or unwilling to complete questionnaires a pro-rated refund will be made, and the agreement terminated.
Ability First Financial, LLC. offers business planning and management solutions on retainer. Ability First Financial, LLC. may require a retainer or minimum engagement for non-investment activities. All proposals reflect disclosure of Investment and non-investment expenses. Examples may include insurance consulting, TPA and/or recordkeeping solutions. Retainers generally have a minimum of $2000 per year are non-refundable and are for Fiduciary and non-Fiduciary services distinct from investment advice and management. The services may be offered alongside investment-related services but are not bundled, all services receive a distinct line item and are distinctly billed for, investment clients need not use, and ancillary services provided by Ability First Financial, LLC. as a condition of service and receive no discount for doing so. Additionally, in the case when fees are to be drawn from accounts plan or participant accounts a bill is sent to the client for approval and the fees are disclosed on the 408(b)2 and other relevant disclosure documents. For example, a 401k Record Keeping solution is currently $15 PE/PM subject to the complexity of the services offered and is inclusive of any fees charged by subcontracted providers, like daily valuation, pricing, statement, and customer service providers. Each subcontracted provider is disclosed on the 408(b)2. Ability First does not offer the option of charging these services based on an asset fee like many providers or in a bundled manner since the cost to provide these services is not related to the size of the account but the number of phone calls a participant makes to customer service, the time they spend using research services and the number of transactions they make per year.
An Investment Management Agreement is executed as an integral part of the relationship. The annual fee for our advisory services (as noted in the Investment Management Agreement) is generally between 1% and 2% depending on variables such as the third-party manager used, the investment vehicles implemented (i.e., mutual fund and ETF expenses ratios,) and the dollar value of the client account. In certain situations, the annual fee may be negotiable.
Ability First Financial, LLC. Regularly uses third-party money managers to provide the best options to clients that would benefit from the use of a specialized portfolio manager. The fees for these third-party money managers is inclusive in the 1% to 2% and is listed in disclosures as applicable.
Ability First Financial, LLC. engages the service of a CPA who is also a CFA. A Copy of the engagement agreement is included as a supplement to this agreement. Tax preparation and/or advice is never bundled with Investment Management Services and always requires a separate agreement.
A Client may terminate any of the aforementioned agreements with a 30-day notice by notifying Ability First Financial, LLC. in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Ability First Financial, LLC. (through the relevant third-party platform) will refund any unearned portion of the advance payment.
Ability First Financial, LLC. may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Ability First Financial, LLC. will refund any unearned portion of the advance payment.
Third-party managers utilized by Ability First Financial, LLC. base their fees on a percentage of assets under management. As previously stated, annual fees are generally between 1% and 2% depending on the third-party manager, the investment vehicles utilized, and the size of the account. In certain situations, the annual fee may be negotiable.
· Less than 1MM 2%
· 1MM to 10MM 1.5%
· 10MM and up 1%
Ability First Financial, LLC. may charge fees not related to investment services including fees that are based on asset values including fees for record keeping.
Ability First Financial, LLC. offers non-investment Insurance products to clients as appropriate. However:
· Variable Insurance products (if deemed appropriate) are only sold when an AUM or zero compensation version is available.
· If neither option is available and the advisor deems the product to be the best option for the client, the advisor will refer the client to the manufacturer or distributor of the said product and will not accept any compensation for the sale.
· Fixed and Equity Index products are deemed to be compliant with Rule 3030, however, Ability First Financial LLC has adopted a fiduciary program to ensure that the client’s best interest is always taken into consideration and procedures are in place to ensure and disclose accordingly.
Even though CFR 29 § 2510.3-21(b) (Employee Benefits
Security Administration, Labor, 2016) the “Fiduciary Rule” is in question.
Ability First Financial, L.L.C. has chosen to implement a Fiduciary framework
to ensure that all clients are aware of the potential conflicts of interest
that exist in the financial world. Please see Fiduciary Framework starting on
Ability First Financial, LLC. Annual Service Minimums and fee structures.
Financial Planning and Business Planning services start at a minimum of $4000 per year and are generally billed annually, however on an exception basis may be paid quarterly for the benefit of the client, quarterly or monthly payments may be subject to a service charge. The Financial Planning and Business planning processes start with a 1-hour free consultation, the prospective client has presented a proposal based on the mutually determined complexity. Pricing is reviewed approximately 90 days before renewal based on experience during the covered period. No surcharges are provided during the year for services covered in the initial agreement. Additionally, the proposal may include the recommendation of other providers or for the client to engage additional services as part of the relationship. For example, Ability First Financial LLC. provides a general discussion on Estate related concerns but is not an Attorney or Affiliated with one.
In an abundance of caution, Ability First Financial, LLC. treats all consulting services regulated or not as if they are regulated, a signed agreement, and a know your customer packet is completed prior to any engagement. Additionally, Ability First Financial, LLC. discloses all potential conflicts as part of its Fiduciary Framework policy which is attached to this document.
Ability First Financial, LLC. provides Financial Planning, Insurance, Record Keeping and Tax Services to its clients. It may engage the use of non-affiliated providers to aid in the offerings.
Clients of Ability First Financial, LLC. have the option to purchase and select investments with other advisors. In doing so clients may select brokers, dealers, distributors or agents other than organization recommended and or vetted by Ability First Financial, LLC. and its affiliates. Clients are free to conduct these transactions on their own, subject to costs and terms set by the vendors of their choice.
Clients need-not use Ability First Financial, LLC ’s recommended platforms and are free to conduct transactions entirely outside with any assistance from Ability First Financial, LLC. When this occurs, the client is charged a reduced advisory fee to cover only the limited scope relationship to the transaction. Such assets are noted on each statement and the billing reflects the relationship.
Third-party investment management fees are billed quarterly (sometimes in advance,) meaning that fees are deducted from client accounts before the three-month billing period has begun. Fees are deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account.
Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security by third-party managers is more important than the nominal fee that the custodian charges to buy or sell the security.
Mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.5% for their services. Exchange Traded Funds (ETFs) also have expense ratios similar to mutual funds but are generally lower than those fees charged by mutual funds. These fees are in addition to the fees paid investment owner to third-party investment managers for their portfolio management services. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted.
In today’s fee-compression environment Ability First Finical, LLC. is keenly aware of the effect of excessive fees on accounts. Ability First Financial, LLC., believes that a higher fee on a similar product should not be an eliminating factor. If however, the product provider demonstrates value for the additional expense, it may be appropriate to use a higher fee product. An Example may include an index fund provided by two different fund companies, the expense ratio may only be one overall factor in the selection of fund, the performance of the fund net of expenses may be a better indicator the selection of investment products.
Ability First Financial, LLC. does not believe that hidden fees are never beneficial for the client. As such, Ability First Financial, LLC. does not accept any 12(b)1 fee, Sub-TA fee or other disclosed or non-disclosed fees from any third-party to any client account. In rare cases, a fund or product that is requested by a client may not be available in a fee-waived version. In that case, Ability First Financial, LLC. works with vendors to return fees directly to plan participant(s) or client(s) accounts wherever possible and permitted by law. If it is not possible, the advisor will discount its fee by an equal amount of the fee received on an as earned basis.
Due to the fact that Ability First Financial, LLC. does not directly custody client assets, and because management fees are generally deducted directly from client accounts, rarely should a past due situation arise. However, Ability First Financial, LLC. reserves the right to stop work on any account that is more than 90 days overdue should that situation arise, and the client waives Ability First Financial, LLC. of any expenses, penalties, losses or expenses during a work stoppage.
In addition, Ability First Financial, LLC. reserves the right to terminate any relationship where a client has willfully concealed or has refused to provide pertinent information, in Ability First Financial, LLC. sole judgment, in providing proper investment advice. Any unused portion of fees collected in advance will be refunded within 30 days. Note: In cases where a planning relationship is terminated due to a client’s failure to comply, a minimum fee may be charged.
Fees are not based on a share of the capital gains or capital appreciation of managed securities.
Ability First Financial, LLC. does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client.
Ability First Financial, LLC. specializes in providing investment advice to Pensions and Qualified Plans, as well as High Net worth individuals, other business owners and select individuals for investment and plan design strategy. Ability First Financial, LLC. also provides consulting and advice to Income Trust and other entities with a focus on long-term tax mitigation strategies.
Client relationships vary in scope and length of service.
Minimum account sizes vary depending on the third-party platform and the specific investment manager used within that platform and are subject to change without notice.
Ability First Financial, LLC. will open individual accounts with less than $100,000 on an exception only basis.
Security analysis methods used by third-party managers may include but is not limited to, charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information may include original fundamental research, financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases.
Other sources of information that third-party managers may use include but are not limited to Morningstar Principia mutual fund information, Morningstar, Advisor Intelligence, and the World Wide Web.
Additional details would be provided in the third-party manager’s disclosures and brochures, when applicable.
Ability First Financial, LLC. believes that individual investment only plays a small part in the overall solutions it provides clients including the management of Levered Planning solutions, the use of qualified plans, engaging in tax planning (with the help of outside tax counsel and or affiliated tax advisors) and the purchase of non-traditional assets that may provide special tax advantages or provide non-correlated risk management from traditional market offerings. As such, third-party managers, mutual funds and ETF’s are regularly used. Ability First Financial, LLC. reviews all fee options and strives to provide the most cost-effective options to purchase investments as needed by its clients.
All investment programs have certain risks that are borne by the investor. Our approach constantly keeps the risk of loss in mind. Investors face the following investment risks:
· Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.
· Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.
· Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.
· Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Currency risk also is also considered when investing in crypto-currency, cash equivalents, and certain alternatives.
· Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
· Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it (a lengthy process,) before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.
· Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.
· Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or declining market value.
· Political and Governmental risk: Changes in tax policy as well as ongoing domestic and international changes in markets.
The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients.
Ability First Financial, LLC. operates as an insurance brokerage, provides tax consulting and preparation as well as providing investment advice.
The employees of Ability First Financial, LLC. have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request.
Ability First Financial, LLC. and its employees may buy or sell securities that are also held by clients. Ability First Financial, LLC. primarily provides planning and qualified plan administration. Direct trades are handled on a limited basis. Advisors may not trade ahead of clients and must disclose similar holdings to any client.
Ability First Financial, LLC. regularly uses third-party managers and as such, it is not aware of the timing of said manager’s trades. Copies of all personal trades are reviewed by the compliance officer to ensure that personal trades are not contrary to the advice provided to clients.
Ability First Financial, LLC. currently uses MidAtlantic Trust Company and National Financial Services for clients based on specific client needs. Additional firms may be used as appropriate for each client’s unique needs.
Ability First Financial, LLC. works with its clients to provide a mix of in-house comprehensive solutions along with other qualified providers. Ability First Financial encourages all clients to compare its offerings to other providers and works to source the best options for each client’s specific needs.
Ability First Financial, LLC. provides relevant Best Execution disclosures for the specific custodian holding the client’s assets (including third-party money managers policies as appropriate.)
Ability First Financial, LLC. provides non-investment related services. All services are individually disclosed. Ability First Financial LLC. does not select supporting vendors or providers based on its other relationships with that vendor. Example: while Ability First Financial LLC. uses Mid Atlantic Trust Company as one of its custodians it additionally uses Mid Atlantic Trust Companies stable value and deposit products each product is selected for its own merits.
Ability First Financial, LLC. does not aggregate orders, however, as a qualified plan administrator, the orders of individual participants may be aggregated to the plan level. Orders are not aggregated past the plan level by Ability First Financial, LLC. or its affiliates.
Client account reviews are typically performed quarterly by Investment Advisor Representatives (IARs). Account reviews are performed more frequently when market conditions or client needs dictate. Since the firm is currently a solo-firm there is no second party to review the IAR however once the firm has additional employees the IAR’s supervisor will review recommendations before they are finalized. Seth Rosenberg will be the final review on all accounts.
Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation.
Investment Management clients receive quarterly report updates. Among other things, these updates detail the portfolio holdings as well as changes and detailed performance reporting. In most cases, clients also have internet access to their accounts if they chose to activate that feature. Internet access would permit clients to view their accounts daily if they so choose.
Ability First Financial, LLC. does not currently offer any referral fees for investment-related services. Non-Investment related services may be subject to their own referral policies and disclosures.
Ability First Financial LLC. does not accept referral fees from any third party however it “White Labels” and works with vendors that may provide enhanced pricing to Ability First Financial LLC. based on its overall relationship with the said vendor. Examples may include tiered pricing discounts with its back office or transaction clearing vendors.
Since Ability First Financial LLC. also operates as an Insurance Agency it may receive commissions for the sale and service of insurance-related products. This inherent conflict is disclosed whenever applicable. In addition, insurance products that contain a regulated component (i.e. Variable Life and Annuities) may only be offered in a fee-only format. Ability First Financial, LLC. takes the position that fixed indexed insurance products remain an exempt product and may be offered on a commission or fee basis with an additional disclosure to the client as appropriate. Additionally Ability First Financial also provides non-custodial record keeping, plan design consulting, document preparation these services may be offered in a Fiduciary or non-Fiduciary compacity and are fully disclosed in any Advisory agreement.
All assets are held by qualified custodians. The custodians provide account statements directly to clients at their address of record at least quarterly.
Clients are urged to compare the account statements received directly from their custodians. In addition, clients may receive additional reports from Ability First Financial, LLC. and its providers.
Ability First Financial, LLC. has an affiliated CFA/CPA, however, this service when offered is provided independently of Investment related fees and services.
Ability First Financial, LLC. may accept discretionary authority on accounts only on a limited basis however, it does not currently have any such accounts at this time.
The client is expected to complete an agreement authorizing the duration of the authority, the portion of the portfolio subject to authority, limitations on the types of investment and investment products, and the size and scope of the authority.
Ability First Financial, LLC. may obtain a limited Power of Attorney for Qualified Accounts to act under the direction of the plan trustees.
Ability First Financial, LLC. does not vote proxies on securities. Clients are expected to vote their own proxies.
Ability First Financial, LLC. does not maintain custody of any securities, but instead works with custodial partners to ensure that clients receive any and all notices due to them via the custodial partners.
Ability First Financial, LLC. will not provide advice on proxy votes.
Ability First Financial, LLC. does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients.
A balance sheet is not required to be provided because Ability First Financial, LLC. does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $500 per client, and six months or more in advance.
Seth Rosenberg has worked with small and large businesses. He is the fifth generation providing insurance and financial planning solutions to businesses and individuals. He currently holds the designation of Life Underwriting and Training Council Fellow from the National Association of Insurance and Financial Advisors and a Baccalaureate in Business Administration from University of Maryland University College and the Global Financial Stewardship designation from 3Ethos
Seth Rosenberg has obtained the Series 7 and 66 and maintains Personal Lines, Life, and Health Insurance licenses as well as the NAIC Model State Education for Long-Term Care and Annuities.
Ability First Financial, LLC. has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key people.
The Business Continuity Plan covers natural disasters such as snowstorms, hurricanes, tornadoes, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, a chemical event, biological event, Internet outage, railway accident an aircraft accident. Electronic files are backed up daily and archived offsite.
Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location, as detailed in Ability First Financial, LLC. Business Continuity Plan.
In the event of Seth Rosenberg’s serious disability or death, Ability First Financial RIA will engage the services of properly licensed providers until such time that the entity can properly cease operations.
Ability First Financial, LLC. maintains an information security program to reduce the risk that personal and confidential information may be breached.
· Global Financial Steward (GFS) 2016
· The GFS® designation is awarded to professionals who complete an approved course of instruction on LeaderMetrics® and pass a comprehensive written final exam. The GFS® is the first and only professional designation which is based on leadership and stewardship. (Trone, Branham, & Wattman, Founders, 2018)
· The GFS® designation requires the designee to have read the LeaderMetrics (Trone, Branham, & Wattman, LeaderMetrics, 2015) book, complete a minimum of 22-hour onsite program of coursework and training, and complete a classroom administered exam.
· 12 hours of continuing education per year is required to maintain the designation. (FINRA, 2018)
· Bachelor of Science in Business Administration and Management 2015
· The University of Maryland University College (UMUC) is accredited by the Middle States Commission on Higher Education and is governed by the USM Board of Regents (University Maryland University College, 2018)
· The Business Administration Bachelor’s Degree is a study of “accounting, business law, ethics, and social responsibility, finance, human resource management, strategic management, organizational behavior, marketing and sales, and statistical analysis” (University of Maryland University College, 2018)
· The American College for Financial Services, Life Underwriting Training Council Fellowship 2014
· The designation was jointly conferred by the American College of Financial Services and the National Association of Insurance and Financial Advisors. Designees where required to complete (5) 8-week courses and 1 self-study course. After each course, a proctored exam was administered. At the time of confirmation, the designee must be a member of the National Association of Insurance and Financial Advisors.
· The American College for Financial Services is accredited by the Middle States Commission on Higher Education and has been since 1978 (The American College, 2018)
· The National Association of Insurance and Financial advisors or NAIFA is one of the Oldest and largest trade organizations in the insurance field founded in 1890 as the National Association of Life Underwriters (National Association of Insurance and Financial Advisors, 2018).
· The designation provides an in-depth understanding of Life Insurance, Disability, and other protection products, how they interact, as well as an ethical framework for Insurance professionals.
Mr. Rosenberg has no disciplinary history to disclose.
Ability First Financial, LLC. is a full-service Financial Services Firm providing Investment, Insurance, Tax and other business consulting services.
Personal Real Estate Holdings: Rental and Investment property in Baltimore, Maryland.
Cub Scout Pack 210, Grand Canyon Council, Boy Scouts of America (The 1st Sabbath observant Kosher Family Pack in the country): Cub Master 2018-Present
Seth Rosenberg receives all compensation related to Financial services through Ability First, LLC, any compensation paid is directed to the entity and disclosed as such.
Seth Rosenberg is responsible for the investment activity of Ability First Financial, LLC.
Mr. Rosenberg has not been involved in/with, or been accused nor found liable for any of the following:
Seth Rosenberg has not been the subject of a bankruptcy petition.
This document is not intended to replace discussions with your advisor or other research you might consider.
Ability First Financial, LLC’s approach is based on Ethotic Leadership and the Universal Framework approach (Trone, Branham, & Wattman, LeaderMetrics, 2015) and are used with permission.
The most up-to-date version of this document is on file at https://www.adviserinfo.sec.gov/. Where you may review the most current version or information about this firm and its advisors. Additionally, some states provide resources to review your advisors and the companies they represent.
The primary Ability First Financial, LLC website is located at www.Ability-First.com however, we use multiple other landing pages to provide an enhanced focus on our service offerings. All publicly available pages are accessible via the main page.
We believe in making sure that you have easy access to information about our organizations and we post regularly in a variety of publicly accessible sites.
Reasons we can share your personal information
Does Ability First Financial LLC., share?
Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes – to offer our products and services to you
For joint marketing with other financial companies
For our affiliates’ everyday business purposes – information about your transactions and experiences
For our affiliates’ everyday business purposes – information about your creditworthiness
For our affiliates to market to you
For nonaffiliates to market to you
Call us at 410-336-6118 or speak with your representative to update your privacy choices.
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. If you’re an existing customer and have opted out previously, you do not need to update your privacy choices again. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
What happens when I limit sharing for an account, I hold jointly with someone else?