Our firm is committed to protecting the privacy of your personal information. In the process of setting up your account, we collect from you or your representative public and private personal information, including your address, telephone and social security numbers, date of birth, certain financial data, and investment objective. We receive this information on documents, through conversations, and in correspondence. We also have information necessary to manage your account, such as your holdings and transaction history, account number and balance, performance calculations, and cost bases. To reconcile your account, your custodian may transmit account information to us or a third-party vendor at our request. The vendor may format and store account information at its site for purposes of assisting us in reconciling data.

We do not disclose private personal information about our current or former clients, including their names, except as required or permitted by law. For example, we must respond to a court order for information, or you may request that we share your account information with a third party. We restrict access to your information to those persons who require that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect your private personal information.

If you conduct business with us through an investment professional, we may exchange information we collect with them or with others at their direction. Because one or more other financial professionals, such as a financial planner, broker-dealer, or bank, are also servicing your account, that firm will have private personal information about you as well. Please review all applicable privacy policies for a complete understanding of how your personal financial information is treated. You may have other privacy protections under applicable state laws. To the extent those state laws apply, we will comply with them with respect to your private personal information. If you have any questions about our policy, please call us.

03/20/06