Privacy Notice

As a general matter, it is and has always been our policy not to disclose information about you to any other party, and to maintain strict security over your personal information. Our firm's Code of Ethics incorporates confidentiality requirements.

Why are you receiving this notice?

• All registered investment advisors are now subject to privacy notice disclosures. You probably receive similar notices from other financial institutions you deal with. We are required to send this notice to you on an annual basis, and suggest that you keep this notice with your files.
• As always, please contact us if you have any questions.

What are the categories of nonpublic personal information about you that we collect?

In our regular course of business, we collect personal information from you based upon the following:

• The data that you provide to us in our contracts and other account opening forms
• Information that we collect when we effect transactions for you
• On-going conversations with you that allow us to provide asset management services to you based upon your needs and goals

What personal information do we disclose to others?

• It is our policy not to disclose any nonpublic personal information about our customers or former customers to any unaffiliated third parties. The only time that we would disclose your nonpublic personal information is to service providers (e.g. brokers, custodians) in the normal day-to-day investment management of your account to complete transactions or move funds that you have requested. We do not share information for broad scale marketing purposes with our affiliated companies.

What would your rights be if we did disclose your nonpublic personal information other than as noted in the above paragraph?

• If our policies were to change and we sought to disclose your personal information to others, we could not do this without your permission. Under those circumstances, you would have the right to “opt-out” of our disclosing that information.
• Since we do not currently disclose any of your information to third parties, you do not need to avail yourself of the right to opt-out. Should our policies change, we would provide you with detailed information prior to implementing any potential change to request your approval and provide you with information on how you would be able to opt-out of us disclosing information about you.

How do we protect your nonpublic personal information that we have in our files?

• We have adopted strict policies and procedures to protect your nonpublic personal information. As stated above, maintaining your confidence is so critical to us that it has been incorporated into the firm's Code of Ethics. In addition, we maintain physical, electronic and procedural safeguards that comply with federal privacy standards to guard your nonpublic personal information.

April 2010