Regulatory Notices

Privacy Notice

Maintaining the privacy of your nonpublic personal information is a priority at Trailmark. In November 1999, Congress enacted the Financial Services Modernization Act, otherwise known as the Gramm-Leach-Bliley Act (“GLB”). GLB provides protection for nonpublic personal information which financial institutions obtain from their customers and other third parties. Please take time to review our privacy policy.

Information Trailmark Receives About You

• Information disclosed on your limited partnership investor qualification questionnaires and subscription agreements
• Other information provided to us by you, including information we may request as part of our Anti-Money Laundering Policy and Customer Identification Program
• Information furnished by third parties, including publicly available information that is lawfully available to members of the general public from one of three sources: official public records (such as real estate records or security interest filings), widely-distributed media (including information obtained over the Internet from public sites on an unrestricted basis), and information required to be made public by federal,state, or local law.

Information We May Disclose to Third Parties

We do not disclose to any third party any nonpublic personal financial information about our customers or former customers without their consent, except: (i) as required by law; or (ii) as described in the following paragraph.

Third Parties to Whom We Disclose Information

Trailmark may only disclose nonpublic financial information to law enforcement agencies or other entities to which we are required by law to disclose such information. Further, when establishing a relationship with new customers, Trailmark may disclose certain nonpublic personal information to third-party information providers contracted by our firm to assist in verifying your identity as part of our Anti-Money Laundering Policy and Customer Identification Program.

Security of Information

Trailmark restricts access to nonpublic personal information about you to our officers only. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal financial information.
(Updated April 20, 2009)

Anti-Money Laundering – USA Patriot Act Requirements

The USA PATRIOT Act requires all financial institutions to obtain, verify, and record information that identifies each person and entity that opens an account. Therefore, for investors that open accounts with fund managers that we represent (i.e., subscribe to funds placed by our firm), certain information must be received prior to accepting an investment in a fund; and either before or after such investment, we must verify this identification information. We will request to view one or more of the following documents in order to verify identification: for an individual, an unexpired government-issued identification evidencing nationality, residence, and bearing a photograph or similar safeguard, such as a driver’s license or passport; and for an entity, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust agreement. Alternatively, we will reference a database or public information source to verify the investor’s identity. Each purchaser will be required to complete an investor qualification questionnaire prior to acceptance of the subscription agreement by the fund manager. The questionnaire will require the investor to disclose information regarding the entity or person that is making the investment in the fund, including a representation that the investor qualifies as either a qualified purchaser or an accredited investor. (Updated April 20, 2009.)

Business Continuity Plan Disclosure Statement

Trailmark Inc. (the Company) plans to quickly recover and resume business operations after a significant business disruption (SBD) and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our company’s business continuity plan (BCP) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD. The BCP addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting. The fund manager (issuer of the limited partnership interests) maintains all records related to your investments and account holdings and backs up important records in accordance with their business continuity plans. For more information on their contingency plans, please contact the fund manager directly at the telephone number provided on your offering documents or through their website. Significant Business Disruptions: The Company’s plan takes into account two kinds of significant business disruptions, internal and external. Internal SBDs affect only the Company’s ability to communicate and do business, such as a fire or loss electrical power in the office or building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services. Internal SBDs: In the event of a disruption in the Company’s business operations due an internal SBD, the Company will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving its operations to an alternative location. If personnel or operations must be moved to an alternate location, the Company anticipates that it will resume regular operations within 2-4 hours. External SBDs: In the event of a disruption in the Company’s business operations due to an external SBD, the Company will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the affected area, if possible, or by providing customers with alternative communication arrangements, as indicated below, to conduct business. The Company will attempt to resume business within 24-48 hours and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances. In all cases, the Company will resume normal business operations as soon as it is able to do so, based on the type and the extent of the disrupting event.

Communications

• Contact the Company at the following alternate telephone number: (212) 235-1081
• Access the Company’s website at www.trailmark.com.
• Contact the fund manager directly at the number listed on the applicable offering  documents or your most recent statement.
• Contact FINRA’s District office at the following telephone number for more  information on the company’s status and additional instructions: 404-237-9290.
• Contact information: Any questions regarding the Company’s Business Continuity Plan should be addressed to: Trailmark Inc., Attn: Chief Compliance Officer, 3379 Peachtree Road NE, Suite 272, Atlanta, GA 30326. (Updated: December 17, 2008)

Customer Complaints

FINRA Website and BrokerCheck