Order Routing Privacy Policy | Business Continuity Plan| Form ADV Part 2A


GW & Wade Privacy Policy -- May 2, 2016

An Important Notice Concerning GW & Wade's Client Privacy

At GW & Wade, LLC and GW & Wade Asset Management Company, LLC (collectively, “GW & Wade”), we believe that it is essential to protect the privacy of client information.  The nature and importance of our client relationships require the highest standards of confidentiality and discretion.  We have prepared this notice to provide our clients with a summary of the non-public information that we may collect and maintain during the course of our relationship, our policy regarding the use of that information and the measures we take to safeguard that information.  We do not sell any client information to anyone and only share certain client information with others as described in this notice.  

Information We Collect

In the course of our advisory relationship, we obtain non-public information about our clients, including:

  • Information we receive from you on account applications or other forms (such as your name, address, social security (or tax identification) number, and information about your employment, income, assets, beneficiaries, tax situation, and investment objectives).
  • Information about your transactions with us or our affiliates (such as account activity and transactions information from other financial advisers with whom you work).
  • Information we might receive from other outside advisers or investment managers or broker-dealers with whom you work.  

Disclosure Policy

We do not disclose any non-public information about current or former clients or their accounts to anyone, except as permitted by law to facilitate our services to clients or as otherwise required by law.  As allowed by law, we share information about current and former clients among our affiliates as necessary to help us service your account with us.  For example, our investment adviser company shares client information with our affiliated broker-dealer in order to process transactions that you request.  We also provide non-public client information to affiliated and non-affiliated companies only to the extent necessary to effect, administer or enforce a transaction that you request or authorize.  In order to complete certain transactions or account changes that you direct or authorize, we may provide non-public client information collected by our firm to companies, individuals, or groups that are not affiliated with GW & Wade.  

In addition, we will release information about you if you direct us to do so, or if we are permitted or required by law, to government and regulatory agencies.  We may also release information in order to comply with a legal summons, court order, subpoena or similar legal process, if required to do so.

Information Security

We have implemented procedures designed to restrict access to your nonpublic client information only to those employees who need it to perform their job.  We maintain reasonable and appropriate administrative, physical, and technical safeguards that comply with applicable state and federal law to safeguard your non-public client information.

You may also view our privacy policy at any time online at www.gwwade.com.


Business Continuity Plan

GW & Wade, LLC and GW & Wade Asset Management Company, LLC have developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us

If after a significant business disruption you cannot contact us as you usually do at (781) 239-1188, or via email, you should go to our web site at www.gwwade.com, for instructions on how to reach us. If you cannot access us through either of those means, you should contact our clearing firm, National Financial Services, LLC at (800) 801-9942 or visit www.nationalfinancial.com for instructions on how it may assist you in gaining access to your funds.

Our Business Continuity Plan

We plan to quickly recover and resume business operations after a significant business disruption 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 business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan 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; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, National Financial Services, LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that it has developed plans designed to account for business interruptions of various lengths and scope. These plans include the ability to recover critical functions according to their time criticality.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within the same business day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and expect to recover and resume business within the same business day. In this situation, GW & Wade, LLC and GW & Wade Asset Management Company, LLC may depend heavily on our clearing firm, National Financial Services, LLC and its business continuity planning. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site, www.gwwade.com or through a voicemail message on our company phone line at (781) 239-1188, with instructions on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For More Information

If you have questions about our business continuity planning, you can contact us at (781) 239-1188. Please note that GW & Wade, LLC and GW & Wade Asset Management Company, LLC’s Business Continuity Plan is subject to modification and is updated at least annually. Updated plans can be obtained by requesting a written copy of the plan by mail or by going to www.gwwade.com.


Investor Education and Protection Disclosure

FINRA Rule 2267

The Financial Industry Regulatory Authority runs a public disclosure program known as BrokerCheck that provides information about brokerage firms and their registered persons. To obtain an investor brochure that includes information about BrokerCheck or to obtain additional information, contact the FINRA public disclosure hotline at (800) 289-9999 or visit the BrokerCheck website at http://brokercheck.finra.org/.  FINRA’s general website is located at www.finra.org/

Disclosure of Financial Condition 

FINRA Rule 2261

Copies of the audited financials of GW & Wade Asset Management Company, LLC, will be provided to any customer upon written request.  Please contact the firm’s Chief Compliance Officer at (781) 239-1188. 

SIPC Information

FINRA Rule 2266

You may obtain information about the Securities Investor Protection Corporation (SIPC), including a copy of the SIPC brochure, by calling them at (202) 371-8300 or visiting their web site at www.sipc.org.