Important Information About Our Privacy Policy

We respect the privacy of all clients and prospective clients (collectively termed “customers” per federal guidelines), both past and present. It is recognized that clients have entrusted our firm with non-public personal information and it is important that both access persons and customers are aware of firm policy concerning what may be done with that information.

The firm collects personal information about customers from the following sources:

Information provided to us complete their plan or investment recommendation; Information provided via engagement agreements and other documents completed in connection with the opening and maintenance of an account; Information customers provide verbally; and Information received from service providers, such as custodians, about client transactions.

The firm does not disclose non-public personal information about our customers to anyone, except in the following circumstances:

When required to provide services our clients have requested;• When our clients have specifically authorized us to do so;

When required during the course of a firm assessment (i.e., independent audit); or When permitted or required by law (i.e., periodic regulatory examination.

Within the firm, access to customer information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices is confidential and they are instructed not to discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes, for example, providing information about a spouse’s IRA account or to adult children about parents’ accounts, etc.

To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information.

The firm will provide the client with its privacy policy on an annual basis per federal law and at any time, in advance, if firm privacy policies are expected to change.