JVB Investment Company

Privacy & Disclosure

Company Privacy Notice

Jack V. Butterfield Investment Company is a full service brokerage firm and SEC registered investment advisor. We can offer you a variety of investment products: stocks, bonds, mutual funds, tax-free investments, annuities, IRA’s and IRA rollovers, SEP Plans, 403(b)’s, Simple plans and 401(k) retirement plans. In order to provide these products, we partner with agencies such as RBC Correspondent Services for our trade clearance and Capital Group – American Funds for direct mutual fund purchases.

Information We Collect

To provide you with professional investment services, we collect non-public personal information (NPI) about you from the following sources:

Information we receive from you on applications or other forms (e.g., name, address, Social Security number, assets, and income).
Information about your transactions with us, our affiliates, or others (e.g., account balances, payment history, and parties to transactions).
Information we receive from consumer reporting agencies (e.g., creditworthiness and credit history).

Sharing Information with RBC Clearing & Custody & Capital Group American Funds

As a small firm, we partner with RBC Clearing & Custody, a division of RBC Capital Markets, LLC, to provide specialized services including trade execution, custody of assets, and the preparation of account statements and tax reporting. We also do significant business with Capital Group - American Funds directly.

We share your information with RBC and American Funds only as necessary to:

Open and maintain your brokerage accounts.
Process and service your transactions.
Comply with legal and regulatory requirements.

Other Sharing Practices

We do not sell your personal information to third parties. We do not share your information with non-affiliated third parties for marketing purposes. We only disclose information to non-affiliated third parties as permitted or required by law, such as to:

Comply with a subpoena or similar legal process.
Respond to inquiries from the SEC, FINRA, or state securities regulators.
Protect against fraud or unauthorized transactions.

How We Protect Your Information

We maintain strict physical, electronic, and procedural safeguards.

Technical Security: We utilize RBC’s secure technology platforms (such as RBC Black or Portfolio Advantage) for data management, ensuring institutional-grade encryption.
Limited Access: We restrict access to your non-public personal information to those employees who need it to provide products or services to you.
Disposal: We employ secure destruction methods (shredding) for any physical documents containing sensitive information.

Your Right to Opt-Out

If you wish to opt out of these disclosures, now or at any time in the future, please contact our office at 517-787-2430. However, please note that if you direct us not share your personal information with our affiliated financial services providers, we may still share your personal information to the extent permitted by law to process transactions and/or to service your accounts.

Former Customers

If you close your account or your relationship with Jack V. Butterfield Investment Company ends, we will continue to adhere to the privacy policies and practices described in this notice.

Contact Us

If you have any questions about this privacy notice or how your information is handled, please contact:

Jack V. Butterfield Investment Co. Attn: Chief Compliance Officer

Phone: 517-787-2430

Address: 100 S. Jackson St. Jackson, MI 49201

Business Continuity

Jack V. Butterfield Investment Co, a Broker/Dealer maintains important disaster recovery and business continuity plans that may be activated in the event of a significant business disruption. The firm realizes the critical nature of being able to continue material operations if an incident occurs that could affect mission-critical business units and systems. These plans are key components in maintaining emergency procedures, and are required by securities industry regulations.

In planning for potential significant business disruptions, JVBCO has looked at a number of scenarios, including, as examples only, a disruption in our building, a city-wide business disruption, and a regional disruption. The firm’s plans are intended to permit the continuation of key business operations during most types of disruptions by resuming mission-critical operations, usually within the same day as the disruption. To assist this business continuity, the firm maintains the back-up technology to continue operations in an alternative location. In cases of extreme disruption, where the continuation of business may not be practical or in the best interest of the firm or its clients, JVBCO has implemented steps to allow clients prompt access to their funds and securities.

However, clients should be aware that because the firm’s plans contain details of a confidential and proprietary nature, they cannot be distributed to the public. Clients should also note that JVBCO’s business plan is subject to modification, and that updated plans will be promptly be posted on JVBCO’s web site as permitted by applicable law.

Please see our Business Continuity Plan below

Business Continuity Plan

Order Routing/Best Execution RBC Clearing & Custody Services

The SEC has directed that all brokers have a duty to regularly and rigorously review their order routing decisions to ensure that client orders are routed to destinations where they are likely to receive “best execution.” Factors that are to be considered in such reviews include overall market quality, including the opportunity for an order to receive price improvement, speed of execution, order size, trading characteristics of a particular security, availability of accurate information affecting choices as to the most favorable market, availability of economic access to the various market centers and the cost and difficulty associated with achieving an execution in a particular market center.

The RBC C&C Best Execution Committee (“the Committee”) is comprised of senior management from RBC C&C Operations and finance. The Committee meets monthly to review statistics and other information pertaining to the execution quality provided by RBC C&C’ order routing destinations as well as competing venues. This review is mandated by RBC C&C’ written supervisory procedures and utilizes execution statistics required to be published by market centers pursuant to SEC Rule 605 and Rule 606, as provided to RBC C&C by S3 Matching Technologies, LP (“S3”). In addition to reviewing statistics and the other factors discussed above, the Committee also reviews order routing processes and technology, and makes suggestions to improve or replace those in place.

For more information, please visit the RBC C&C Page Here.

USA PATRIOT Act Information

Below is important information about our procedures for opening an account mandated by the USA PATRIOT Act.

To help the government fight the funding of terrorism and money laundering activities, the USA PATRIOT Act, a federal law, requires all financial institutions to obtain, verify and record information that identifies each person who opens an account, including business accounts.

When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents. If you are opening an account on behalf of a business entity, documents relating to the business may also be requested.