*This regulation supersedes AR 340–21, dated 5 July 1985.. AR 25–22 • 22 December 2016 UNCLASSIFIED i Headquarters *Army Regulation 25 – 22 Department of the Army

We protect the integrity and privacy of your information in a number of ways. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to our customers. Regulation S-P is the SEC’s primary rule pertaining to the privacy notices and safeguard policies of Registered Investment Advisors (“RIAs”) and broker-dealers. On April 16, 2019, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Regulation S-P Risk Alert, which summarized the findings of RIA and broker 5) The privacy notice must conform with the model form 6) Notify member's annually of the availability of the privacy notice 7) Member is provided opportunity to opt-out of information sharing in a place other than the annual privacy notice The GLBA and Regulation P require that financial institutions provide consumers with certain notices describing their privacy policies. 14 Financial institutions are generally required to provide an initial notice of these policies when a customer relationship is established and to

The Risk Alert is intended to assist advisers and broker-dealers in complying with the privacy and opt-out notices, as well as adopting and implementing effective policies and procedures for safeguarding customer records and information, under Regulation S-P.

The model privacy form is designed to make it easier for consumers to understand how financial institutions collect and share their personal financial information and to compare different institutions’ information practices.

The new privacy notice will be treated as an initial privacy notice for purposes of this regulation and the financial institution’s obligation to provide an annual privacy notice thereafter shall be determined in accordance with the requirements and exceptions of this section.

The model privacy form is designed to make it easier for consumers to understand how financial institutions collect and share their personal financial information and to compare different institutions’ information practices. In December, President Barack Obama signed into law the Fixing America’s Surface Transportation Act. Buried on page 476 of this 490-page bill is an amendment to the consumer privacy provisions of the Gramm-Leach-Bliley Act (the GLBA) that eliminates the annual privacy notice requirement for certain financial institutions, as further described below. The privacy policy is a promise that a company is protecting its customers Regulation S-P requires a firm to provide a privacy policy to its customers at initial application and once every