
March 30, 2026
We are in a highly regulated business, which offers our clients important protections. There are certain disclosures that we are required to make regularly regarding our policies and procedures, including:
The nature of our business requires us to obtain sensitive personal and financial information from our clients. As a registered investment adviser with the United States Securities and Exchange Commission (SEC), we must adopt policies and procedures to protect this nonpublic, personal information. Our policy mandates that ACM employees are prohibited from disclosing nonpublic, personal information to any person or entity outside of our firm, except as authorized by our clients or an appropriate regulatory institution. We also take all reasonable measures to ensure secure transfer and/or disposal of documents containing sensitive information about our clients. You can find our privacy notice posted on our web site and in the ACM portal. It is also available upon request.
Additionally, registered investment advisors are required to file regulatory compliance documents with the SEC or state securities regulators on an annual basis. A copy of our updated Form ADV Part 2 and CRS is available at any time upon request, or it may be downloaded from our website and will be available in the ACM portal. If you would like a paper copy of any of these documents, please let us know.