CITY NATIONAL ROCHDALE FUNDS STATEMENT OF PRIVACY PRINCIPLES
City National Rochdale Funds and its affiliates know our shareholders expect and rely upon us to maintain the confidentiality and privacy of all of the information about them in our possession and control. Maintaining the trust and confidence of our shareholders is our highest priority. We are, and always have been, committed to maintain the confidentiality of shareholder information.
We have adopted and published these privacy principles to guide our conduct when we collect, use, maintain or release shareholder information and to assist our shareholders and others to better understand our privacy practices in general and as they apply to nonpublic personal information in particular.
First, we understand our moral, professional and legal obligations to our shareholders, former shareholders and other protected persons to maintain the privacy of all the confidential information about them in our possession and control. We will obey all applicable laws respecting the privacy of this information and will comply with the obligations of the law respecting nonpublic personal information provided to us. We regularly review and test our procedures and our technology to determine that this information is safeguarded to our satisfaction and as required by law.
Second, we collect, use and retain the information, including nonpublic personal information, about our shareholders and prospective shareholders that we believe is necessary for us to understand and better meet their financial needs and requests, to administer and maintain their accounts, to provide them with our products and services, to anticipate their future needs, to protect them and us from fraud or unauthorized transactions, and to meet legal requirements. We may share this information with our affiliates as permitted by law because some of our products and services are delivered through or in conjunction with our affiliates.
Third, we instruct our colleagues to limit the availability of all shareholder information within our organization to those colleagues responsible for servicing the needs of the shareholder and those colleagues who reasonably need such information to perform their duties and as required or permitted by law.
Fourth, we review our records and use our technology to determine that the shareholder information we maintain is accurate, current and complete and is processed promptly. We will respond quickly to a request to correct inaccurate information.
Fifth, we do provide shareholder information, including nonpublic personal information, to our vendors and other outside service providers whom we use when appropriate or necessary to perform and enhance our shareholder services. When we provide shareholder information to anyone outside our organization we only do so as required or permitted by law. We require all of our vendors and service providers, who receive shareholder information from us, to agree to maintain the information in confidence, to limit the use and dissemination of the information to the purpose for which it is provided and to abide by the law. We monitor or otherwise determine that each outside vendor and service provider receiving nonpublic personal information from us complies with our confidentiality requirements. To the extent permitted by law, we undertake to advise a shareholder of any government or other legal process served on us requiring disclosure of information about that shareholder.
Sixth, except as stated above, we limit our disclosure of nonpublic personal information to third parties to the following circumstances:
Seventh, we maintain security standards and procedures to respond to the risk of unauthorized access to shareholder information.
- When requested to do so by the shareholder;
- When necessary, in our opinion, to effect, administer, or enforce a shareholder initiated transaction; and
- When required or permitted to do so by law or regulation, including authorized requests from government agencies and if we are the victim of fraud or otherwise suffer loss caused by the unlawful act of the shareholder.
Eighth, we educate all our colleagues about these privacy principles and their obligations to maintain confidentiality and privacy of shareholder information as described in this Statement and we take appropriate disciplinary measures to enforce these obligations.
We reserve the right to alter or amend this Statement and any of the policies or procedures described above at any time. Terms used in this Statement have the meaning given in Title V - "Privacy" of the Gramm-Leach-Bliley Act (Public Law 106-102, codified at 15 U.S.C. 6801 et seq.) or the regulations prescribed under that Act.
Should you have any questions regarding the Funds' Privacy Principles, please contact your investment professional or the Funds at 1-888-889-0799.
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