Pursuant to Regulation S-P adopted by the Securities and Exchange Commission, it is the policy of Comprehensive Asset Management and Servicing, Inc., and Comprehensive Capital Management, Inc. (together “Comprehensive”) to keep confidential nonpublic personal information (“information”) pertaining to each current and former client (i.e., information and records pertaining to personal background, investment objectives, financial situation, investment holdings, account numbers, account balances, etc.) unless Comprehensive is :

(1) previously authorized by the client to disclose information to individuals and/or entities not affiliated with Comprehensive, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.);

(2) required to do so by judicial or regulatory process; or

(3) otherwise permitted to do so by law. 

The disclosure of information contained in any document completed by the client for processing and/or transmittal by Comprehensive in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Comprehensive (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated  third party service provider.  Each individual and/or entity affiliated with Comprehensive is aware of Comprehensive’s Privacy Policy, and has acknowledged his/her/its requirement to comply with same.  In accordance with Comprehensive’s Privacy Policy, each such affiliated individual and/or entity shall have access to information to the extent reasonably necessary for Comprehensive to perform its services for the client, and to comply with applicable regulatory procedures and requirements.

Should you have any questions regarding the above, please contact Ronald S. Rollins, Vice-President, Compliance of Comprehensive at (973) 394-0404.