THIS DOCUMENT CONTAINS IMPORTANT INFORMATION ON OUR CONCERN FOR PROTECTING YOUR RIGHTS UNDER FEDERAL PRIVACY LAWS.

1. We collect personal information about you and all our clients from the information you submit on our applications or other forms, and through information we obtain over the course of your business relationship with us, our affiliates, and others. In addition, we may from time to time receive information about you from a consumer reporting agency.

2. Personal information is information that we collect from you that is not otherwise available from public sources. The categories of personal information we collect include the following:

a. Information we receive from you on applications or other forms, such as your name, address, social security number, names of family members, assets, and income.

b. Information about your transactions with us, our affiliates, or others, such as your account balances, investments, current and prior tax information, and credit card usage.

c. Information we may receive from a consumer reporting agency pertaining to your creditworthiness and credit history, including loan or mortgage payments made.

3. We will not disclose any personal information about our clients or former clients to anyone, consistent with our professional confidentiality obligations. However, upon your written request we will disclose information about you, and we may be required by law to disclose personal information about you, as, for example, in response to a subpoena or other court order. Also, we may disclose personal information about you to our affiliated financial planning and investment advisor firms.

4. Within our institution, we provide access to your personal information only to those employees who need to know the information to provide you with our services. We maintain physical and procedural safeguards to guard your personal information.

5. We do not share your personal information with companies that perform marketing services.