DISCLOSURES

To Our Clients
CapWealth is a Registered Investment Advisor.

CapWealth treats client privacy and security as our highest priority. It is and will remain the cornerstones of our commitment to you. We are dedicated to keeping the trust you place in us. We understand that you want to know how we treat the personal and professional information that we obtain from you or other sources in the course of providing you with services and products.

Privacy protection is a responsibility we take seriously. That is why we would like to take this opportunity to explain to you that as our client, we are committed to safeguarding your personal information.

Please read this notice entirely as it contains information regarding your rights under certain U.S. privacy laws and CapWealth privacy policy. We may amend this notice from time to time and will provide you with a revised notice as appropriate.

Privacy Notice
This Privacy Notice covers the personal information of individuals who are current and former clients of CapWealth.

Part of what you expect from CapWealth is information—such as information about the history of transactions in your account or current market information. However, the information you provide to us is equally important. This Privacy Notice is intended to provide you with a full understanding of the information we collect about you and our guidelines for sharing and safeguarding that information with others.

Confidentiality and Security
We consider the information we have about you to be confidential, including the fact that you are a CapWealth client (unless you tell us otherwise). Your information will be handled in the manner described in this notice. We restrict access to information about you to those employees and authorized agents who need to know that information. We maintain physical, electronic and procedural safeguards that comply with federal standards to maintain the confidentiality of your information.

Information We Collect
Much of the personal information that we have about you comes directly from you. You disclosed much of this information to us during the course of our business relationship. We may have contacted you by telephone, e-mail or regular mail for additional information.

We may use your personal information for investment purposes or to help you with your overall investment program. We may also use your personal information to communicate with you about products or investments that you have expressed an interest in or that we believe may be of interest to you.

At CapWealth, we collect the following types of information about you:

• Information you provide on new account forms, applications, or agreements you enter into in order to receive our products or services, including your name, address, social security number, income, and investment objectives;
• Information about your transactions with us; and
• Information from a consumer reporting agency (for example, your credit history or other facts relating to creditworthiness) or from other parties or sources such as public databases.

Should your relationship with CapWealth end, your personal information will remain protected in accordance with our privacy practice as outlined in this Notice.

Third Parties to Whom We Disclose Information
We do not disclose any personal information to companies or organizations not affiliated with CapWealth that would use the information we have provided to contact you about their own products and services. We do not sell information about our current or former clients. When we share personal information with companies working on our behalf, we protect that personal information where required by law with a confidentiality agreement that obligates those companies to conform to our standards and keep confidential any information about you that we may give them.

Some examples of legally permitted sharing or disclosures to third parties include:

• Sharing of information to properly manage our business. This includes sharing information to service your accounts, to comply with laws, and for other routine business practices. For example, we may share information with third parties to process your statements, to comply with court orders, or for tax reporting.
  
• To companies who perform marketing or research services on our behalf or with whom we have joint marketing agreements. These include companies performing marketing services on our behalf, such as mailing materials advertising our products or services, performing research, or assisting us with evaluating our client service quality.
  
• Regulatory or law-enforcement authorities. When required by any legal or regulatory authority, documents will be provided.
  
• To other parties as authorized by you. You may direct us, for example, to send your account statements and confirmations to third parties.

To Our Clients
CapWealth will not tolerate money-laundering activity. We are committed to our policy to prohibit and actively prevent money laundering and any activity that funds terrorist or criminal activities.

To help the government fight the funding of terrorism and money laundering activities, Federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What This Means for You
When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see and copy your driver’s license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, partnership or trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience, objectives and risk tolerance.

If your identity cannot be established, CapWealth may not be able to open an account or carry out transactions for you.

To address interruptions to our normal course of business, CapWealth maintains a business continuity plan. The plan is reviewed annually and is updated as necessary.

The firm’s policy is to respond to a Significant Business Disruptions (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business.

The plan outlines the actions CapWealth will take in the event of a SBD, including:

• Continuous processing support by personnel located in alternative physical locations
• Maintaining our client relationships for our mission critical functions of order taking and entry
• Ensure our clearing firm maintains a business continuity plan and has the means to execute the plan

Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure—particularly telecommunications—can affect actual recovery times.

To See Our ADV Form
If you wish to see the firm’s Form ADV Part 1, please click here. To access ADV Part 2A, please click here.

To See Our FORM CRS

To access our firm's Form CRS, please click here.

To Contact Us
If you would like a copy of our ADV Part 2B or have any questions, please don’t hesitate to contact us by telephone at (615) 778-0740 or by e-mail at contactus@capwealthgroup.com.