Data Policy

Custodian and Record Keeping Data Sources

CircleBlack will load and normalize Transactions and daily Positions on a go-forward basis from the following custodians:

  • Axos Advisor Services (fka TCA)
  • Axos Clearing
  • CNB
  • Fidelity
  • Goldman Sachs Advisor Services (fka Folio Institutional)
  • Interactive Brokers (aka IBKR)
  • Pershing
  • RBC C&C
  • Schwab
  • SEI
  • TradePMR (aka FCW)
  • And financial institutions available through ByAllAccounts

CircleBlack will load historical Transactions and historical daily Positions for accounts at the following custodians, if available, for the following durations:

Custodian
Duration
Schwab
Two years

Data Terms for Active Firms

Data will be available for accounts according to the following:
Data Type
High Availability Storage
Cold Storage
Transactions
Rolling 2 years
Since inception of account
Positions
Rolling 2 years
Since inception of account
Daily Position Performance Calculations
Rolling 2 years
Since inception of account
Daily Account Performance Calculations
Rolling 2 years
Since inception of account
Monthly Account Record
Since inception of account
N/A
Monthly Position Record
Since inception of position
N/A

Historical Data Conversion

CircleBlack will gather and load historical Monthly Account Records from the following providers, if available from the provider, for the following durations:
Provider
Duration
Morningstar
Since account inception (up to five years)
The Performance Calculations in the Monthly Account Records will be linked to CircleBlack’s go-forward Performance Calculations

  • Limited to time-weighted rate of return, net and gross of fees
  • Does not include closed accounts

Data Retention Terms for Inactive Firms

Ninety days following termination of service from CircleBlack, a backup of Firm data will be created and made available for Firm access on a shared file storage for ninety days

Data Security and Availability

The CircleBlack platform has been engineered with robust security measures to safeguard sensitive financial data. Utilizing advanced encryption standards for data at rest (AES 256-bit) and in transit (TLS), CircleBlack ensures data confidentiality and protection against unauthorized access.

Access to data within CircleBlack is tightly controlled through role-based access control (RBAC) and reinforced by multi-factor authentication (MFA), reducing exposure to internal and external risks.

CircleBlack maintains a SOC 2 Type I Certification, affirming its adherence to maintaining standards in security, availability, processing integrity, confidentiality, and privacy. These comprehensive security practices underscore CircleBlack’s dedication to maintaining the integrity and security of advisor and investor data, providing a trustworthy and secure foundation for wealth management operations.

Visit the CircleBlack Trust Center
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There’s a confidence that comes with being able to stand behind your technology and the suite of features it offers when conducting business development. It may sound trivial, but knowing that the technology will be a non-issue, hit-it-out-of-the-park experience for the client is a huge benefit… Clients trust me and, by extension, CircleBlack to keep their sensitive data secure.
Tom Toth

Tom Toth

Founder

Toth Capital Management

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