TwinFocus continually invests in our technology and information systems and training to secure privacy and ensure compliance. We are dedicated to the highest ethical and fiduciary standards, and our culture of compliance and trust permeates across our entire firm, from investment management and advisory, planning to developing operational procedures. Our compliance procedures include routine internal mock audits, comprehensive compliance training and regular meetings.
We are dedicated to accessing the best technology in the industry and security protection for our clients, constantly looking for ways to promote greater security and protection.
TwinFocus and its operating partners maintain redundant systems across our entire technology infrastructure and database platforms to ensure continuity of business operations in the event of systemic disaster or loss of key personnel. We also maintain strict internal policies to ensure the safety of our personnel. A copy of the TwinFocus Business Continuity Plan is available upon request.
TwinFocus Capital deploys the latest tools to manage and protect sensitive information. Enterprise level firewalls and antivirus software within our private cloud network keep data secure from unauthorized users.
While we maintain redundant processes to prevent errors in client accounts, in the unlike event that an error does occur, TwinFocus and our partners and service providers maintain Errors & Omissions insurance coverage and liability coverage against fraudulent acts.
Our clients are often considered insiders of major publically traded corporations under federal securities laws, have large positions in certain securities, sit the Boards of various firms, or maintain special relationships with certain publically traded firms. TwinFocus employees and their immediate family members are specifically forbidden from trading and investing in these securities at all times to avoid violation of federal and/or state securities laws, as well as the perception of impropriety. Our Compliance Team conducts regular audits of employee investment and brokerage statements to assure compliance of these internal mandates.
Our recordkeeping and reporting system provides the foundation for our analytical and portfolio management capabilities. It incorporates both privately and publically held assets across multiple custodians, allowing for holistic reporting across the entire family balance sheet, inclusive of liquid investments and outside illiquid holdings. Our technology platform is state-of-the-art and has been designed to provide accuracy, efficiency and safety in transactions, reporting, and privacy of information.
TwinFocus is a Registered Investment Advisor with the Securities and Exchange Commission, subject to government regulation and oversight at the federal and state levels.
TwinFocus does not maintain custody of any client assets nor are client assets commingled with assets of the firm. Custodians have very rigorous security and fraud protection/detection systems, as well as systems to ensure best efforts executions for securities transactions, and integrity of data delivery and money movements.
In addition to legacy client custodial relationships, TwinFocus maintains custodian relationships primarily with Schwab Institutional, Fidelity Investments, JP Morgan, UBS, MorganStanley, and Boston Private Bank, all of which are regulated by multiple state and federal authorities and agencies. Clients receive statements directly from the custodian confirming trade executions, wire transfers, transactions, holdings, and asset transfers.
At TwinFocus, we serve as Fiduciaries to our clients on all matters within the scope of our relationship. Our primary duty as fiduciaries is to manage a prudent investment process, taking into consideration the complete and unequivocal interest of our clients at all times. Our entire team remains legally and ethically bound to act under a strict duty of care and loyalty. We also take great care in assuring our clients’ assets and privacy is protected, with internal controls and written compliance procedures that provide an added layer of assurance against malfeasance.