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OSTERMAN, POLLACK & MOSES, LLC

Privacy Policy

February 15, 2005

To Our Clients:

At Osterman, Pollack & Moses, LLC, protecting the confidentiality of our clients’ records and information is extremely important to us.

We respect your right to keep your personal information confidential and to avoid unwanted solicitations. Be assured that this firm has always considered our professional relationship with you to be one requiring the utmost trust and confidence. In order to provide you with comprehensive tax and financial planning information, we do share some of your personal data as the occasion arises with other service providers who may be able to assist you with your overall tax and financial plans. We consider this information sharing to be a valuable part of the services that we are able to provide to you. If you do not wish us to continue to share this information, for whatever reason, please contact us and we will make arrangements to comply with your request.

So that you understand our policy regarding your information, below is our firm’s current Privacy Disclosure Statement. Please read this to learn how we handle your information.

ANNUAL PRIVACY DISCLOSURE STATEMENT

Types of Information We Collect:
We collect nonpublic personal information about you that is provided by you or obtained by us with your authorization to prepare your personal income tax returns for you.

Examples of Sources from which We Collect Information:

CLIENT INTERVIEWS, TAX RETURN ORGANIZERS, FINANCIAL PLANNING ORGANIZERS, AND FINANCIAL HISTORY QUESTIONNAIRES

To properly prepare your income tax return or provide financial planning services, we receive information from you to complete your tax return or financial plan. This information is collected from you in written form, by phone, on line, by mail and in personal interviews and consultations conducted by us, as well as by information we collect from others with your authorization.

TRANSACTION INFORMATION

This is information about your transactions with us and includes information necessary for billing and payment for our income tax preparation and financial planning services, as well as all correspondence between you and us. Transaction information would also include your payment history with us, billing records and any collection effort engaged in by us for payment of services rendered to you.

Parties To Whom We Disclose Information:
We do not disclose any nonpublic personal information about our clients or former clients to our affiliates or to nonaffiliated third parties except as permitted by law, the Code of Professional Conduct of the Maryland Association of Certified Public Accountants (MACPA) and Ethics Rulings of the American Institute of Certified Public Accountants (AICPA). Nonpublic personal information about you and former clients may be disclosed to both our affiliates and nonaffiliated third parties as permitted by law, our Code of Professional Conduct, and Ethics Rulings of the AICPA, as follows:

To comply with a validly issued and enforceable subpoena or summons.
In the course of a review of our firm’s practices under the Maryland State Board of Accountancy authorization.
By initiating a complaint or responding to an inquiry made by the Professional Conduct Committee of the MACPA, the ethics division or trial board of the AICPA or a duly constituted investigative or disciplinary body of another State CPA Society or Board of Accountancy.
During a review of a professional practice, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser does not disclose information obtained in the course of the review.
Participating in actual or threatened legal proceedings or alternative dispute resolutions necessary to file, pursue or defend against the lawsuit and to take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
Providing information to nonaffiliated third parties who perform services or functions for us pursuant to a contractual agreement which prohibits the third party or affiliate from disclosing or using the information other than for the purposes for which the information was disclosed: for example, using an outside service bureau or third-party service providers to prepare portions of or process clients’ tax returns, or using a records-retention agency to store clients’ records.
To financial service providers, such as mortgage bankers, securities broker-dealers and insurance agents, as we, in our judgment, deem may be worthwhile to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

General Restrictions on Disclosure of Nonpublic Personal Information to
Affiliates and Nonaffiliated Third Parties
As tax preparers, we are prohibited by Internal Revenue Code Section 7216 from disclosing your income tax return information without your consent, other than for the specific purpose of preparing, assisting in preparing or obtaining and providing services in connection with the preparation of an income tax return for you. Furthermore, as a member of the MACPA engaged in income tax preparation or financial planning, we are generally prohibited from disclosing confidential client information about you to affiliates and nonaffiliated third parties without your specific consent. (See exceptions under the heading “Parties to whom we disclose information”)

Confidentiality and Security of Nonpublic Personal Information
We restrict access to nonpublic information about you to those employees and other parties who must use that information to provide services to you. Their right to further disclose and use the information is limited by applicable law, our Code of Professional Conduct and nondisclosure agreements where appropriate. We also maintain physical, electronic, and procedural safeguards in compliance with applicable laws and regulations to guard your Nonpublic Personal Information. Please do not hesitate to call if you have any questions whatsoever about this Disclosure Statement.