Contact Information

Mark Crain
Senior Vice President
Investor Services Manager
800.249.3700

Florida Office
17755 US Hwy 19 N
Suite 400
Clearwater, FL 33764-6500
Ph. 877.654.1500
Fax 727.450.0750

gryphon icon Privacy Notice

Commonwealth’s Privacy Policies and Practices:

Commonwealth does not disclose any nonpublic personal information about our current or former investors to any non-contractual third parties, except as permitted by law. We reserve the right to disclose all categories of the nonpublic personal information, as required by SEC, FINRA, State, or Federal regulations, contractual obligations or other applicable obligations, but only as permitted or required by law (such to protect against fraud or in response to a subpoena).

Examples of third-parties with contractual obligations to receive your personal information are: our legal counsel, our auditing firm, our third-party Investor Database Service Vendor (Phoenix American Financial Services, Inc.), who performs business operations on our behalf, such as mailing of distribution checks, mailing of quarterly or annual reports and mailing of tax information, escrow agents for our offerings, a third party shredding company and an electronic storage media company, as required by SEC Rule 17a-4. We reserve the right to disclose in the future to different non-affiliated third parties, not for marketing purposes, but to provide investor services or as required by law.

Eligibility

Our investors become protected under our policies once they have been approved by the general partner or Manager as a limited partner or member in any of our public or private funds, or when an existing investor newly subscribes to an additional fund.

Delivery

Our investors will receive initial privacy notices with their first investment confirmation and additional privacy notices with each subsequent investment confirmations in a different fund, and additionally will receive a copy with their tax information package each year. Once a fund liquidates and dissolves or an investor prematurely withdraws their investment with general partner/manager approval (heavy restrictions apply – please see prospectus), the obligation to deliver privacy notices to those investors will cease.

How we secure your assets and protect your information:

  • We authorize disclosure to only a limited group of employees with password-protected restricted use;
  • We train our employees to protect investor information;
  • All investor information is kept in locked, secure areas;
  • We continually change and enhance our security systems;
  • We’ve contracted with an independent shredding company(s) for confidential disposal of information;
  • We protect investor data by asking you for information that only you would know when you contact us.

Categories of Nonpublic Personal Information collected:

  • Information provided by an individual to a financial institution to obtain a financial product or service from such institution (e.g. information provided on an application or subscription agreement);
  • Information about an individual resulting from any transaction with the financial institution (e.g. transaction history);
  • Information obtained about an individual in connection with providing a financial product or service to such individual (e.g. information from a credit report);
  • A list, description or other grouping of individuals (and publicly available information pertaining to them) that is derived from nonpublic personal information (e.g. a list of individuals’ names and street addresses derived using such individuals’ account numbers); and
  • The fact that an individual is or has been a customer of a financial institution.

Information About Former Investors

While in the ordinary course of business we do not actively distribute any personal information concerning former investors (i.e., investors in liquidated funds or who have withdrawn from our partnerships or LLCs), certain entities involved in the offerings of the prior funds may retain such information. Also, we reserve the right to disclose all categories of the nonpublic personal information on former investors as required by SEC, FINRA, State, or Federal regulations, contractual obligations or other applicable obligations, but only as permitted or required by law (such to protect against fraud or in response to a subpoena).

We strive to maintain accurate information on your account.

If you would like to order additional privacy notices or believe your account information is not correct, please let us know by calling our toll-free Investor Hotline: (800) 249-3700, to speak to an Investor Services Representative.