Steadworth Right to Financial Privacy Act (RFPA) Policy

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to protecting the financial privacy of its customers in accordance with the Right to Financial Privacy Act ("RFPA"). This Policy outlines Steadworth's procedures for responding to requests for customer financial records from government authorities.

II. Policy Statement

Steadworth will only disclose customer financial records to government authorities in compliance with the RFPA and other applicable laws and regulations.

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents who handle customer financial records. It covers all requests for customer financial records from government authorities.

IV. Definitions

• Customer: Any person or authorized representative of that person who utilizes or has utilized any service of Steadworth.

• Financial Records: Any record held by Steadworth pertaining to a customer's relationship with Steadworth.

• Government Authority: Any agency or department of the United States, or any officer, employee, or agent thereof.
  
  

V. General Requirements

Steadworth will not release customer financial records to any government authority unless the government authority provides:

• A signed authorization from the customer;

• A search warrant;

• A judicial subpoena;

• A summons or administrative subpoena; or

• A formal written request.
  
  

Steadworth will also require the government authority to certify in writing that it has complied with the applicable provisions of the RFPA.

VI. Customer Authorization

A customer may authorize the disclosure of their financial records by providing Steadworth and the government authority with a signed and dated statement that meets the requirements of the RFPA.

VII. Exceptions to General Requirements

There are certain exceptions to the notice and certification requirements of the RFPA. For example, Steadworth may disclose financial records to supervisory agencies or in response to a lawful proceeding, investigation, examination, or inspection.

VIII. Responsibilities

A. Compliance Officer:

• The Compliance Officer is responsible for overseeing and implementing this Policy.

• This includes developing and maintaining procedures, providing training to employees, and monitoring compliance with the RFPA.
  
  

B. All Employees:

• All employees are responsible for complying with this Policy and reporting any potential violations to the Compliance Officer.
  
  

IX. Training

Steadworth will provide regular training to its employees on RFPA compliance. This training will cover topics such as the definition of financial records, notice and certification requirements, customer authorization, and exceptions to the general requirements.

X. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

XI. Conclusion

Steadworth is committed to protecting the financial privacy of its customers. This Policy is intended to ensure that all employees are aware of their obligations under the RFPA and that Steadworth conducts its business in a compliant manner.

XII. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at: contact@steadworth.com

Please note: This Policy is intended to supplement, not replace, any other applicable Steadworth policies or procedures.