August 1, 2009
Montebello Partners has 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.
If after a significant business disruption you cannot contact us as you usually do, you should call our alternative number, below, or visit our web site, www.thebetafund.com, for updated information.
OUR BUSINESS CONTINUITY PLAN
We plan to quickly recover and, where reasonable, 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 back up 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.
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 24 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 48 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our customer numbers (845-368-2900 or the alternate number, 914-682-2052) or web site of current contact information. If the business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.
FOR MORE INFORMATION
If you have questions about our business continuity planning, you can contact Oliver Pursche by phone at 845-368-2900 or by email at firstname.lastname@example.org.
Proxy Voting Disclosure:
Montebello Partners does not generally have authority to vote proxies on behalf of clients. The firm does, however, have this authority where it acts as General Partner for private investment vehicles. Montebello Partners will vote proxies in the best interests of the partnerships and will disclose material conflicts of interest. Montebello Partners written procedures addressing proxy voting and the handling of material conflicts are available to clients upon written request.
Code of Ethics:
Montebello Partners has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. Montebello Partners Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and sets forth Montebello Partners practice of supervising the personal securities transactions of supervised persons with access to client information. Individuals associated with Montebello Partners may buy or sell securities for their personal accounts identical to or different than those recommended to clients. It is the expressed policy of Montebello Partners that no person employed by Montebello Partners shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients.
To supervise compliance with its Code of Ethics, Montebello Partners requires that anyone associated with this advisory practice with access to advisory recommendations provide initial/annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. Montebello Partners requires such access persons to also receive approval from the Chief Compliance Officer prior to investing in any IPOs or private placements (limited offerings).
Montebello Partners requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Montebello Partners Code of Ethics further includes the firm's policy prohibiting the use or misuse of material non-public information. Any individual not in observance of the above may be subject to discipline.
Montebello Partners will provide a complete copy of its Code of Ethics to any client upon written request to the Chief Compliance Officer at Montebello Partners principle address.
Register a Complaint:
All inquiries, complaints and other correspondence should be sent to:
Attn: Chief Compliance Officer
75 Montebello Road
Suffern, NY 10901
This site has been published in the United States for residents of the United States. The foregoing has been prepared solely for informational purposes, and it is not an offer to buy or sell or a solicitation of an offer to buy or sell any security or instrument or to participate in any particular trading strategy.
Much of the information offered on this site is offered through third-party independent vendors and non-affiliated market sites. Montebello Partners offers no opinion as to the accuracy or timeliness of any information provided within this site, nor offers any guarantees as to the accuracy or timeliness of any information contained within this site. Consumers and/or members of the public should not exclusively rely upon this information when considering investments decisions.
Montebello Partners, and any of its employees acting as an agent, may transact business in a particular state only if first registered, excluded or exempted from registration requirements either individually or as a firm. In addition, follow-up conversations or meetings with individuals in a particular state by either Montebello Partners, or its employees acting as agent to effect transactions in securities or discuss securities, investment planning or other personal investment advice will not be made without first becoming registered, excluded or exempted from registration requirements either individually or as a firm. Member FINRA & SIPC.
With passage of the USA PATRIOT Act and SEC approval of the Treasury Department's Customer Identification Rules, Montebello Partners must notify all public and institutional clients of its obligation to verify their identity. Verification of identity will take place through various means, such as comparing information provided by the client against databases like Equifax or Lexis/Nexis, requiring photocopies of a driver's license, passport, or alien registration card, or obtaining other documents of attestation as to that client's identity.
The Management of Montebello Partners would like to thank all clients for their cooperation in assisting the firm in doing its part to maintain the integrity of the U.S. securities markets.
*Mutual Funds involve risk including possible loss of principal
*Beta- is a measure of the volatility, or systematic risk of a security or a portfolio in comparison to the market as a whole.
*ETF Risk- an investor will indirectly bear the fees and expenses charged by the underlying ETFs; and an ETF generally carries the same investment risk as the portfolio of securities within the ETF.
*Hedging/ Derivative Risk- the fund may execute an investment strategy or hedge by entering into derivative contracts such as futures, options or futures and swaps which can be riskier than traditional investments because they involve leverage, may be illiquid, may suffer counterparty default and may limit gains.
*Foreign Risk- investing in foreign securities presents risk not associated with domestic investments, such as currency fluctuations, political and economic changes and market risks.
*Leveraging Risk- The use of leverage, such as borrowing money to purchase securities will magnify the fund’s gains or losses.
Investors should consider the investment objectives, risks, charges and expenses of this fund carefully before investing. This and other information are contained in the fund’s prospectus, which may be obtained by contacting your financial advisor, by visiting www.thebetafund.com or by calling 1-877-464-3111. Please read this prospectus carefully before you invest or send money.
The GMG Defensive Beta Fund is distributed by Northern Lights Distributors, LLC.