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 operation 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 backup 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.

Our clearing firm, National Financial Services, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operation and be able to complete existing transactions and accept new transactions and payments within 72 hours. Your orders and request for funds and securities could be delayed during this period.

If You Are Concerned
If you have any concerns about your accounts or investments, or suggestions on how we may better serve you, please contact us at 412-367-3880 or 800-899-3880 or by email at comments@alleghenyfinancial.com.

For More Information
Allegheny website
Financial Industry Regulatory Authority website
U.S. Securities & Exchange Commission website
Securities Investor Protection Corporation website

The Allegheny Code of Ethics and Code of Conduct are sets of principles and guidelines that define the professional conduct we expect of our advisors, representatives, and employees. These values represent who we are. They describe our intended state of being. They are so integral to our being that we would not abandon them even if we were penalized for holding them. We realize our duty and responsibility to place the investor first. These Codes work in tandem with the Financial Industry Regulatory Authority (FINRA) Rules of Conduct and all other applicable Standards of Professional Conduct.

Allegheny Code of Ethics

INTEGRITY
We conduct ourselves in a manner that reflects honorably upon Allegheny.

COMPETENCE
We provide all financial services with superlative knowledge and skill. This requires not only lifelong learning but also the continual assessment of our ability to appropriately and effectively address the needs of those we serve.

FAIRNESS
We are fair and reasonable in all of our dealings with clients, principals, partners, employees, associates, and each other, and disclose all conflicts or potential conflicts of interest.

DILIGENCE
We provide our services in a prompt and thorough manner, with outstanding planning and supervision.

OBJECTIVITY
We provide our financial services in an objective and unbiased manner.

CONFIDENTIALITY
We do not disclose any confidential information without the specific consent of our client unless we are compelled to do so pursuant to proper legal process, or in judicial or regulatory proceedings.

PROFESSIONALISM
We epitomize the best and highest ethical standards of the financial services profession.

STEWARDSHIP
We recognize our responsibility to act with vision, ever mindful of the effects of our actions today and tomorrow on the future.

Code of Conduct
Allegheny and its agents shall observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business. Acts and practices, including but not limited to the following, are considered contrary to such standards and may constitute grounds for denial, suspension, or revocation of registration, termination of employment, or such other action authorized by statute and Allegheny policies.

As a registered representative of Allegheny I will not:

  • Induce trading in a customer’s account that is excessive in size or frequency in view of the financial resources and character of the account.
  • Recommend to a customer the purchase, sale, or exchange of any security or other investment without reasonable grounds to believe that such transaction or recommendation is suitable for the customer. I will make this recommendation based upon reasonable inquiry concerning the customer’s investment objectives, financial situation and needs, and any other relevant information known by the broker-dealer.
  • Execute a transaction on behalf of a customer without authorization to do so.
  • Exercise any discretionary power in effecting a transaction for a customer’s account without first obtaining written discretionary authority from the customer, unless the discretionary power relates solely to the time and/or price for the execution of orders.
  • Execute any transaction in a margin account without securing from the customer a properly executed written margin agreement promptly after the initial transaction in the account.
  • Enter into a transaction with or for a customer at a price not reasonably related to the current market price of the security, and will not receive an unreasonable commission, fee, or profit.
  • Effect any transaction in or induce the purchase or sale of any security or other investment by means of any manipulative, deceptive or fraudulent device, practice, plan, program, design or contrivance, which may include, but not be limited to:
    • Effecting any transaction in a security that involves change in the beneficial ownership thereof.
    • Entering an order or orders for the purchase or sale of any security with the knowledge that an order or orders of substantially the same size, at substantially the same time, and substantially the same price, for the sale of any such security, has been or will be entered by or for the same or different parties for the purpose of creating a false or misleading appearance of active trading in the security, or a false or misleading appearance with respect to the market for the security. I understand that nothing in this subsection shall prohibit me from entering bona fide agency cross transactions for my customers.
    • Effecting, along or with one or more other persons, a series of transactions in any security creating actual or apparent active trading in such security or raising or depressing the price of such security, for the purpose of inducing the purchase or sale of such security by others.
  • Guarantee a customer against loss in any security or other investment account.
  • Publish or circulate, or cause to be published or circulated, any notice, circular, advertisement, newspaper article, investment service, or communication of any kind which purports to report any transaction as a purchase or sale of any security unless I believe that the transaction was a bona fide purchase or sale of the security.
  • Use any advertising or sales presentation in such a fashion as to be deceptive or misleading. I will not distribute any non-factual data, material, or presentation based on conjecture, unfounded or unrealistic claims or assertions.
  • Lend or borrow money or securities to or from a customer, and will not act as a custodian for money, securities, or an executed stock power for a customer.
  • Affect securities transactions not recorded on the regular books or records of Allegheny, unless Allegheny Compliance authorizes the transactions in writing prior to the execution of the transaction.
  • Establish or maintain an account containing fictitious information in order to execute transactions which would otherwise be prohibited.
  • Share directly or indirectly in profits or losses in the account of any customer without Allegheny’s written authorization.
  • Divide or split my commissions, profits, or other compensation from the purchase or sale of securities with any person not also registered with Allegheny.
  • Purchase a new issue of securities (hot issue) that trades at a premium in the immediate after market for my account or the account of my immediate family, contrary to the Free Riding and Withholding Interpretational Memorandum of NASD.

As a registered representative of Allegheny I will:

  • Fully and completely disclose any and all outside business activities and private securities transactions to Allegheny, and will not participate in such activities until I receive written permission from Allegheny to do so.
  • Furnish customers purchasing securities with a prospectus for the offering. I will furnish this information no later than the date of confirmation of the transaction.

Securities Reporting Requirements for Access Persons

APPLICATION OF THE CODE OF CONDUCT TO ACCESS PERSONS OF ALLEGHENY
The provisions of this section apply to every security transaction, in which an Access Person of Allegheny has, or by reason of such transaction acquires, any direct or indirect beneficial interest, in any account over which he has any direct or indirect control. Generally, an Access Person is regarded as having a beneficial interest in those securities held in his or her name, the name of his or her spouse, and the names of his or her minor children who reside with him/her. An Access Person may be regarded as having a beneficial interest in the securities held in the name of another person (individual, partnership, corporation, trust, custodian, or another entity) if by reason of any contract, understanding, or relationship he obtains or may obtain benefits substantially equivalent to those of ownership. An Access Person does not derive a beneficial interest by virtue of serving as a trustee or executor unless the person, or a member of his/her immediate family, has a vested interest in the income or corpus of the trust or estate. However, if a family member is a fee-paying client, the account will be managed in the same manner as that of all other Allegheny clients with similar investment objectives.

If an Access Person believes that he should be exempt from the reporting requirements with respect to any account in which he has direct or indirect beneficial ownership, but over which he has no direct or indirect control in the management process, he should so advise the CO in writing, giving the name of the account, the person(s) or firm(s) responsible for its management, and the reason for believing that he should be exempt from reporting requirements under this Code.

USE OF PRONOUNS
Words used in this document in the masculine shall be read and construed in the feminine or neuter where required by the context in which they are used. Words in the singular shall include the plural and vice versa where the context so requires.

ON BECOMING AN ACCESS PERSON
Any employee of Allegheny who during the course of his employment becomes an Access Person must provide the CO with an Initial Securities Holdings Report no later than 10 days after the employee becomes an Access Person. This report must include the following information:

  • A list of securities, including the title, number of shares, and/or principal amount (if fixed income securities) of each covered security in which the Access Person had any direct or indirect beneficial interest or ownership as of the date the employee became an Access Person;
  • The name of any broker, dealer or bank with whom the Access Person maintained an account, or in any other account in which securities were held for the direct or indirect benefit or ownership of the Access Person; and
  • The date the report is submitted to the CO by the Access Person.

QUARTERLY TRANSACTION REPORTS – RULE 204-2(A)(12) OF THE ADVISERS ACT
Every Advisory Representative and/or Access Person must submit a Personal Securities Trading Report to the CO not later than 10 days after the end of each calendar quarter listing all securities transactions executed during that quarter in the Access Person’s brokerage account(s) or in any account(s) in which the Access Person may have any direct or indirect beneficial interest or ownership. The quarterly Personal Securities Trading Report must contain the following information:

The date of each transaction, the name of the covered security purchased and/or sold, the interest rate and maturity date (if applicable), the number of shares and/or the principal amount of the security involved;

The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

The price at which the covered security was effected;

The name of the broker, dealer or bank through whom the transaction was effected; and

The date the report is submitted to the CO by the Advisory Representative and/or Access Person. (Note: The report must be submitted to the CO within 10 calendar days following the end of the quarter.)

ANNUAL SECURITIES HOLDINGS REPORT
Every Access Person must submit an Annual Personal Securities Holdings Report to the CO listing all covered securities held by the Access Person as of December 31 of each year. The report must be submitted not later than 10 calendar days following year-end and must be current as of a date no more than 30 days before the report is submitted. The Annual Personal Securities Holding Report must contain the following information:

The title, number of shares and principal amount (if fixed income securities) of each covered security in which the Access Person had any direct or indirect beneficial ownership interest or ownership;

The name of any broker, dealer or bank with whom the Access Person maintains an account in which any covered securities are held for the direct or indirect benefit of the Access Person; and

The date the annual report is submitted by the Access Person to the CO.

In addition to the reporting provisions of sub-sections 5.3 and 5.4, above, Access Persons will be required annually read and sign Allegheny’s Code of Conduct regarding employee securities transactions.

REPORTS OF ASSOCIATES’ SECURITIES TRADES IN ACCOUNTS WITH BROKER/DEALERS
All Associates of Allegheny having account(s) with any broker/dealer must ensure that the account(s) are established so that duplicate copies of trade confirmations and monthly account statements are submitted directly to Allegheny by the broker/dealer.

In lieu of manually listing each securities transaction on the Personal Securities Trading Report, an Associate may affix (staple) copies of trade confirmations received during that quarter to his/her report.

NEGATIVE REPORTS
Although the Rule 204-2(a)(12) and Rule 17j-1 do not require negative reports, it is the policy of Allegheny that Personal Securities Trading Reports be submitted quarterly by all associated persons whether or not securities transactions have occurred in their accounts during the period. Those associates having no securities transactions to report must indicate this fact in his/her quarterly report. The report must then be dated, signed and submitted to the CO for review.

Allegheny Financial Group, Ltd. and Allegheny Investments, Ltd. (“Allegheny”) are committed to safeguarding the confidential information of our clients. We hold all personal information provided to us in the strictest confidence. These records include all personal information we collect from you in connection with any of the services provided by Allegheny. We do not provide your personal information to mailing lists vendors or solicitors for any purpose. We do not disclose information to non-affiliated third parties, except as required by law. We only use health and financial information that you provide to complete a service or transaction which you have requested. We maintain a secure office and computer environment to ensure that your information is not placed at risk.

We limit employee and agent access to information only to those who have a business or professional reason for access. Federal regulations permit us to share a limited amount of information about you in order to execute securities transactions or process an insurance application on your behalf.

For unaffiliated third parties that require access to your personal information, including financial service companies, insurance companies, consultants, and auditors, we require strict confidentiality clauses regarding information privacy. Federal and state regulators also may review firm records as permitted by law.

Federal laws exist to assist the government with its efforts to fight the funding of terrorism and money laundering activities. All financial institutions are required to obtain, verify, and record information that clearly identifies its new and existing clients. When opening an account, we will request to see your driver’s license or any other federally acceptable form of identification. We will also ask for your address, date of birth, and any other federally required information as printed on the Universal Account Application. We are also mandated by federal securities law to update all existing client information every three (3) years.

This information will be maintained during the time you are a client and up to six (6) years following the termination of association as required by federal and state securities laws. After such required time, all information will be professionally destroyed.

We at Allegheny Financial Group recognize and respect the sensitive nature of information collected over the World Wide Web and the right of consumers to protect it. It is for this reason we disclose and abide by this Privacy Policy.

Information Collection and Use
From time to time, we may collect personally identifiable information you voluntarily provide in order to obtain our products and services, or information about them, and to comply with requirements of regulators, if any. Personally identifiable information may include, but is not limited to, first and last name, street address, zip code, email address and phone number.

We also collect site visitor information by monitoring customer traffic patterns and site usage to help us tailor our services to meet your ever-changing needs and enhance the experience of visitors to our web site. We collect some basic and anonymous information about your computer when you visit our web site including, but not limited to, your IP address, the operating system used by your computer and your browser software.

Cookies
A “cookie” is a small data file that some web servers transmit to a user’s browser when the user visits a web site. A cookie file can contain information, such as a user ID, which the site uses to track the pages users visited. A cookie can’t read data off a hard disk against your will, destroy files, send viruses or read cookie files created by other sites. The only personal information a cookie can contain has to be supplied by the user.

We use cookies solely to track user traffic patterns when users register for access to restricted areas of this site. We also use cookies to allow you to move more easily and securely through our site. When users register, we use a cookie to store the user identifying information. Cookies enable users to enter various parts of our site as a registered user without having to log on each time, and to visit other restricted areas of the site with similar security settings.

Disclosure of Information Concerning Customers and Former Customers
We will not sell, trade or rent your data in personally identifiable form without your permission. We may disclose nonpublic personal information as required by law and may disclose such information (if permitted by law) upon the request of a law enforcement agency or presentation of a court order or subpoena.

We may share certain aggregated, anonymous demographic and statistical information our website visitors with state and federal agencies to comply with regulatory requirements. None of this information contains information that would identify you and connect you to your nonpublic personal information.

We also may, from time to time, use the information we collect to notify you of changes to our services, announce new services and inform you of special offers we think you might find valuable.

We do not share any user information with any other parties, including advertisers.

Protecting Customer Information
The personal information that you provide to MFSN is considered confidential information by MFSN and we protect this information in several ways. Your personal confidential information resides on a secure server to which only selected MFSN representatives have access, via password.

Opt-Out Policy
Users may choose not to provide information to us and/or not to allow us to use cookies in connection with their visit to our site. To opt out of providing information directly to us, simply bypass or elect not to participate in the interactive areas of our site. You may opt out of allowing us to use cookie technology to facilitate your visit to our site by making adjustments to your browser; however, it is possible that this site will not function properly if you do so.

Accessing, Correcting and Updating Information
You have the right to access, review and correct your personal information collected by us. You may do so by sending an email to: advisorservices@alleghenyfinancial.com Please be sure to include your name, address and/or email address on the form.

Changes to Privacy Policy
This privacy policy sets forth our current practices and procedures with respect to privacy. We reserve the right, at our discretion, to change, modify or alter all or portions of this policy at any time. If our policy changes in the future, the updated policy will posted here so that you will have the latest information on our data collection and use procedures. This policy was last updated on June 22, 2001.

Complaints, Comments, Concerns
You may contact us with respect to any complaints, comments or concerns regarding our privacy policy at compliance@alleghenyfinancial.com.
PLEASE NOTE THAT WE ARE NOT RESPONSIBLE FOR THE CONTENT OR PRIVACY PRACTICES OF OTHER WEBSITES TO WHICH OUR WEBSITE MAY LINK.

Your Acceptance of These Terms
By using this site, you signify your assent to our privacy policy. If you do not agree to this policy, please do not use our site.