Collection or Receipt of Information

In the course of rendering investment management services to Financial Advisors, FAS may request and/or receive non-public, personally identifiable information pertaining to the Financial Advisor’s client from the Financial Advisor and the custodian or other service providers. The information may include identifying and financial information (the “Information”).

Use of the Information

FAS will use the Information for its internal purposes in rendering investment management services and may disclose the information to its service providers, if any, in conjunction with such purposes. Otherwise, FAS will not disclose the Information to any other party except as may be pursuant to legal process or as may be required by law.

Safeguard of the Information

FAS will employ reasonable and prudent procedures and practices to protect the Information from loss, theft, or inadvertent disclosure.  Additionally, FAS will comply with all privacy laws as may be applicable and with the terms and conditions of its agreements with parties from whom it may receive the Information.