GIPS Disclosure

GIPS is a registered trademark of the CFA Institute. CFA Institute does not endorse or promote Commonwealth Investment Management, nor does it warrant the accuracy or quality of the content of this website.

Definition of Firm

• Commonwealth Investment Management (“CIM”) is an SEC-registered investment adviser located in Pittsburgh, PA. CIM provides investment management services to institutional funds including public pension plans, endowments, eleemosynary accounts and Taft-Hartley funds throughout Pennsylvania and the region. CIM is a privately held corporation whose primary line of business is investment management services.

Availability of Additional Information

• A list and description of CIM’s composites and/or GIPS reports may be obtained by either emailing us at info@ciminvests.com or by writing to us at Commonwealth Investment Management, Koppers Building, 436 Seventh Avenue, Suite 2600, Pittsburgh, PA 15219.

GIPS Compliance Statement

• CIM claims compliance with the Global Investment Performance Standards (GIPS^®).

Collection of Private Information

CIM recognizes that the relationship we have with our clients is our most important asset. For this reason, CIM is committed to maintaining the security, confidentiality and integrity of our current and prospective clients’ nonpublic personal information. As part of this commitment, CIM adheres to the highest standards concerning the collection, disclosure and maintenance of such private information.

In the course of establishing and providing investment advisory services CIM collects:

• Information that is received when the account is opened, such as account information and contact names, addresses and phone numbers.
• Information such as trade tickets and account statements generated through advisory services, reports from third parties such as custodian statements or brokerage house statements.

Disclosure of Private Information

CIM will not sell any current, prospective or former clients’ information to any third party.

CIM will not disclose any nonpublic personal information relating to our current or prospective clients unless one of the following conditions is met:

• Written consent from the client has been received or the information is to be disclosed to persons acting in a fiduciary capacity on the client’s behalf.
• CIM is fulfilling legal and regulatory requirements through regulatory organizations, industry associations and similar bodies.

Maintenance and Disposal of Private Information

CIM has taken steps to ensure that clients’ nonpublic information is maintained and disposed of in accordance with all federal and industry standards and that each employee of CIM adheres to the CIM Code of Conduct pertaining to clients’ nonpublic personal information.