As you may be aware, federal privacy laws require that we explain to you how we handle “nonpublic personal information.” This is the information that in the course of my relationship with you, we receive or develop about you. It includes (1) information you provide to us orally or on applications and other forms, and (2) information we develop about you in the course of providing my services to you, such as the amount and type of assets that we manage and transactions we place on your behalf.

As a general rule, we do not disclose this private information to others. As you might imagine, however, we rely on third parties for services that are necessary to enable us to provide our services (investment) to you. These include attorneys, auditors, prime brokers, and custodians who, in the ordinary course of providing their services to us, may require access to information containing your nonpublic personal information. In addition, we may disclose your nonpublic personal information to others with your consent, where required by law or judicial process (such as a court order), or otherwise to the extent permitted under the federal privacy laws.

We also restrict access to your nonpublic personal information among our personnel. Only those who need the information in order to help us provide services (investment advisory) to you have access. It is our policy that, where we are not comfortable a service provider is not already bound by duties of confidentiality (e.g., attorneys and auditors), we will require contractual assurances that they will maintain the confidentiality on any of your information they obtain. We also maintain (physical, electronic, and procedural) safeguards to guard your nonpublic personal information.

If you have any questions about our practice with respect to your nonpublic personal information, you may contact us by phone at 310-373-3732.