Disclosures

Code of Ethics

BuffaloFirst Wealth Management, LLC has adopted a Code of Ethics to assist employees in carrying out its duties as a fiduciary to its clients. The Code of Ethics is based upon the principle that BuffaloFirst Wealth Management, LLC and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid:

(i) serving their own personal interests ahead of clients,

(ii) taking inappropriate advantage of their position with the firm,

(iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility.

The Code of Ethics is designed to maintain BuffaloFirst Wealth Management, LLC’s high ethical standards. Existing or prospective clients may contact BuffaloFirst Wealth Management, LLC for a full copy of the Code of Ethics.

Privacy Policy

We consider privacy as fundamental to the relationship with our clients. Accordingly, we have developed policies and procedures to protect the confidentiality, integrity and security of client information and to help achieve compliance with relevant rules and regulations. We hold our employees accountable for complying with those policies, procedures, rules and regulations

Information We May Collect

We endeavor to collect, use and maintain client information only for appropriate purposes.  We may collect and maintain the following nonpublic personal information about you:

    • Ÿinformation we receive from you on applications or other forms, such as your name, address, email address, tax identification number, telephone number, account number, and other relevant account information; and
    • Ÿinformation about your transactions with us, our affiliates or others, such as your account number, balance, positions, activity, history, and other financial information.

Information We May Disclose or Share

We do not disclose any nonpublic personal information about our clients or former clients to any third parties, except as permitted or required by law or for the purposes of servicing client needs.  We are permitted by law to share any of the information we collect, as described above, with our affiliates.  BuffaloFirst Wealth Management, LLC will share information with affiliates if the information is required to provide a product or service you have requested.  We may also share your personal information relating to transactions and experiences with affiliates for their everyday business purposes.  In addition, we may share information about clients or client accounts with affiliates in order to make clients aware of services that BuffaloFirst Wealth Management, LLC thinks may be of interest or value to them.  Marketing from our affiliates may also include invitations to events.

We may share information with non-affiliated third parties to the extent necessary to effect, process, administer or enforce a transaction that you request or authorize, in connection with maintaining or servicing your account, as requested by regulatory authorities, or as otherwise permitted or required by law.  For example, we may provide such information to companies that perform various services such as auditors, attorneys, outside investment managers, or custodians.  We may also disclose information to non-affiliated parties if compelled by law, such as responding to a subpoena, preventing fraud, or complying with an inquiry by a government agency or regulator.

How We Protect Your Information

We restrict access to nonpublic personal information about you to those persons who need to know that information to provide services to you.  We maintain physical, electronic, and procedural safeguards to protect the confidentiality, integrity, and security of your nonpublic personal information.  Any party that accepts or receives nonpublic personal information from us is obligated by contract or by law or regulation to keep this information confidential and to use the information only for those purposes that we specify or as required.

We will continue to adhere to the privacy policies and practices in this notice even if your account is closed or becomes inactive.

Affiliate Marketing Opt-Out

Clients may limit BuffaloFirst Wealth Management, LLC’s affiliates from marketing their services based on personal information that we collect and share with them.  Your choice to limit marketing offers from our affiliates will apply until you request a change to your choice.  If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again.

How to Contact BuffaloFirst Wealth Management, LLC

To limit marketing offers or for questions about our privacy policy, please contact BuffaloFirst Wealth Management, LLC at (716) 861 -7371 or by mail at 7606 Transit Rd. Suite 100, Buffalo, NY 14221.

BFWM ADV Part 2A 2017

Kevin R Connolly ADV 2B BFWM 2016

Allen C Dembski ADV Part 2B BFWM 2017

Taunya Abaya ADV 2B BFWM 2017

Buffalo First Investment Advisory Agreement

Buffalo First Financial Planning Agreement 01-01-14

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