Privacy Policy

We recognize that your personal or account information is important to you. Comstock Partners, LLC (“Comstock”) has developed the following privacy standards regarding this information.

Comstock does not sell your personal information.

Comstock may use third party service providers for its internal purposes. Any third party service providers that Comstock may use will be bound by obligations of confidentiality not to disclose the information provided by Comstock about its customers and may not use this information for any purpose other than performing the particular service.

We use the e-mail address you provide to us to send account information and other important administrative information to you.

Disclosing information in other situations

Under certain circumstances, we may be required by law to disclose your personal information. Comstock may also disclose personal information to protect its legal rights or to enforce our Customer Agreement. We may disclose certain Customer Information to credit bureaus and similar organizations, and otherwise when permitted by law. For example, this may include:

  • A disclosure in connection with a subpoena or similar legal process;
  • A fraud investigation;
  • Recording of deeds of trust and mortgages in public records;
  • An audit or examination;
  • The sale of your account to another financial institution.

Information Security

We are committed to preventing others from authorizing access to your customer information, and we maintain procedures and technology designed for this purpose. We take several steps to protect the customer information we have about you, including the following:

  • We maintain physical, electronic and procedural safeguards to protect your information;
  • We restrict access to information about you to those employees who need to know that information to provide you with the best possible products and services;
  • We require outside companies and independent contractors to whom we provide customer information for marketing, servicing or processing purposes to enter into a confidentiality agreement that restricts the use of such information to be used for specific purposes as intended, and prohibits the independent use of such information;
  • We update and test our technology on a regular basis in order to improve the protection of customer information;
  • We have internal procedures that limit access to customer information to only those members who are considered “authorized” personnel.

If you have any questions about your personal or account information or about Comstock privacy policies and practices, please feel free to contact us at (310) 278-6444.

NASD Public Disclosure Information

NASD Conduct Rule 2280, requires the following information be provided to you: (1) The NASD Regulation, Inc. Public Disclosure Program hotline number is 1-800-289-9999; (2) The NASD Website address is, www.nasdr.com, and (3) The NASD has a brochure available describing the public disclosure program.

Money Laundering

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institution to obtain, verify, and record information that identifies each person who opens an account. What this means for you;

  • 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.

For any further information regarding these disclosures, please feel free to contact us.

Comstock Partners, LLC’s Business Continuity Planning

Comstock Partners, LLC 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.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at our main office, you should call our alternative number 310-367-5252. If you cannot access us through either of those means, you should contact our bookkeeping firm, Kathleen Suite at (949) 786-4659.

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 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.

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 48 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 and notify you through our web site www.comstockpartners.com or our customer emergency number, (310) 278-6444 or (310) 367-5252 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 (310) 278-6444.

SIPC Disclosure

Comstock is a member of the Securities Investor Protection ("SIPC"), which provides account protection for the net equity of a customer's funds and securities positions. SIPC provides $500,000 of primary net equity protection, including $100,000 for claims for cash ("SIPC Coverage"). Visit www.sipc.org for more information about SIPC Coverage. Account protection applies when a SIPC member firm fails financially and is unable to meet its obligations to its securities customers, but does not apply to losses from the rise or fall in the market value of investments or to SIPC ineligible assets such as futures, foreign exchange transactions, or any investment contracts that are not registered as securities