You have provided us with certain Nonpublic Personal Financial Information (NPI) in connection with establishing your account and providing investment advisory services to you.  This information will generally be derived from information we receive from you on questionnaires, applications and other forms used in the process of establishing and maintaining our relationship with you. It is also derived from information about your securities transactions with us, other advisor firms we do business with and with broker/dealers that may be providing financial services to you or acting on our mutual behalf in providing financial services to you.

 We restrict access to your personal and account information to our personnel and third party service providers.  Further, we always maintain physical, electronic and other safeguards to guard your non-public information.  If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.   

 As part of our Privacy Policy, we will obtain your written permission before we would disclose (NPI) about you outside of certain permitted exceptions (i.e. chiefly related to the needs of the business to provide services to you).   Our representatives may be registered representatives, i.e. affiliates, of other entities that maintain certain accounts held with our firm as introducing broker for a clearing broker.  As such, as referenced above, we will disclose customer information to and receive customer information from these entities. Additionally, we have a relationship with other investment advisor firms that may assist us in supervising and or managing your account.  As such, we will disclose customer information to, and receive customer information from these firms.

 Exceptions.  There are exceptions that allow Brown Advisory Group, LLC to disclose your NPI to persons or firms that are non-affiliated third parties (NTP’s) without prior permission. The exceptions include but are not limited to:

 The NPI is necessary to service or process a transaction or a financial product or service requested or authorized by the Consumer or Customer. 

•  The NPI is necessary to provide some ancillary recording or reporting of the transaction, product or service, account maintenance, confirmation, accruing fees or bonuses, etc.
•  The NTP has a legal or beneficial interest relating to the Consumer or Customer or is acting in a fiduciary or representative capacity.
•  The disclosure is for the purpose of protecting the confidentiality or security of Brown Advisory Group, LLC’s records, or to prevent potential or actual fraud, unauthorized transactions, claims or other liability, for institutional risk control or resolving customer disputes or inquiries.
•  Subject to the Right to Financial Privacy Act, the disclosure is to a law enforcement agency, regulator, self-regulatory agency or in a public safety investigation.
•  The disclosure is to comply with federal, state or local laws, rules or regulations, including requirements of self-regulatory organizations or a subpoena or judicial process.

 The information sharing practices described previously are in accordance with Federal law.  In states where your affirmative consent is required before we can disclose your personal information, we will comply with those state laws. 

 IN SUMMARY, BROWN ADVISORY GROUP, LLC DOES NOT DISCLOSE ANY CONSUMER OR CUSTOMER NON-PUBLIC INFORMATION TO NON-RELATED THIRD PARTIES OTHER THAN IN CONTROLLED CIRCUMSTANCES AS SPECIFICALLY ALLOWED BY REGULATION S-P.