Triloma Securities, LLC is registered as a broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”; http://www.finra.org), and is affiliated with Triloma Financial Group and Triloma Energy Advisors, LLC (hereinafter collectively referred to as “Triloma”). In its capacity as a broker-dealer, Triloma is primarily engaged as Dealer Manager for select public and private investments. Occasionally, Triloma also may serve as the introducing broker-dealer of record for certain unsolicited transactions.
Why does Triloma handle nonpublic personal information?
In the course of accepting instructions to facilitate certain transactions, Triloma may obtain or have access to nonpublic personal information about investors, potential investors, family members, trustees, directors and other affiliates. Triloma maintains physical, procedural and electronic safeguards to protect the privacy of every person whose nonpublic information it obtains or accesses. This statement describes those safeguards.
What information does Triloma maintain or access?
In connection with the execution of certain transactions, Triloma may request information that includes names, physical and electronic addresses, Social Security numbers (and other tax identification numbers), account balances, net worth, birth dates, investments, driver’s license numbers and employment status. Such information may also be obtained with respect to any investor’s joint applicants. This information is required to meet obligations set by the SEC and FINRA for broker-dealers.
What does Triloma do with the information it maintains?
The nonpublic personal information Triloma maintains is used to provide support for the transactions that have been requested. Such information may be disclosed to third parties as necessary to provide broker-dealer services. Third parties could include transfer agents, custodians and investment sponsors and their representatives. In addition, Triloma may be required to share personal information with federal, state and regulatory agencies or if Triloma receives a court order requiring the disclosure in connection with a proceeding that involves an investor. Transfer agents, custodians and investment sponsors are required to maintain strict privacy policies. Triloma’s agents operate under an agreement that requires them to safeguard nonpublic personal information to the same degree as Triloma. Triloma does not provide such information to any person or entity other than those who have a need to know nonpublic personal information in order to execute transactions and as set forth above.
How does Triloma safeguard nonpublic personal information internally?
Triloma maintains physical, electronic and procedural safeguards to protect nonpublic personal information. Such information may be stored in either hard copy or electronic format (or both).
- Physical Safeguards:
- Certain records are stored in print and are maintained in a locked filing cabinet located within the secure premises of Triloma’s offices. Access to Triloma’s offices is restricted to authorized personnel, and Triloma’s offices are locked with a security alarm system and armed at all times except during normal business hours.
- Electronic Safeguards:
- Information is stored on a cloud-based server, accessible by active Triloma employees who supply authenticated user IDs and passwords. Access to this server is password protected and access to specific documents is restricted to those needing access to perform their job duties. Any nonpublic personal information transmitted by Triloma across public networks or via wireless transmission is encrypted prior to transmission.
- Procedural Safeguards:
- All Triloma employees have signed contracts prohibiting them from disclosing nonpublic personal information to any third party except in furtherance of investor and potential investor goals on a need-to-know basis. Employees receive training that stresses the importance of safeguarding nonpublic personal information and are educated on policies regarding storage, access and transportation of records outside of business premises.