Legal & Regulatory

Capital & Credit International, Inc. (CCII), is a fully disclosed broker-dealer with clearing services and custodianship executed by Pershing, LLC, a subsidiary of The Bank of New York Mellon Corporation. CCII is owned by Capital & Credit Holdings Inc.

• Privacy Policy Statement
• Business Continuity Statement
• Conflict Resolution Statement

Disclosures

• Investor Protection
• Anti-Money Laundering Disclosure

Privacy Policy Statement

In opening and servicing its customers' accounts CCII will collect the following personal information:

• Identifying information, e.g. customers' name, address, telephone number, social security number, or other official identifying information.
• Application information, e.g. information about customers' assets, income, investment goals and risk preferences; and
• Transactions information, e.g. account activity information

CCII will use its customers' personal information in ways that comply with the purposes for which the information was obtained. CCII, for example, will use customers' information to process the customers' requests and transactions, to provide customers additional information about products and services, and to evaluate customers' financial needs and suitability for particular products and services.

CCII will share customers' personal information with its agents or affiliates, and with its clearing firm. CCII will limit the collection and use of personal information to what is necessary to administer its business and to deliver professional services to its customers. Such services may include advising the customer about the firm's products and services, the products and services of CCII's affiliates, and other opportunities that may be of interest to customers.

CCII will not share personal information with others except as stated in this policy, and unless it gives its customers additional notice or obtains their permission to do so. However, CCII reserves the right to disclose or report customers' personal information:

• To CCII's clearing firm, as CCII deems necessary or appropriate to handle, process and clear transactions in accounts.
• Where CCII believes in good faith that disclosure is required under law to cooperate with regulatory agencies and law enforcement authorities.
• To perform necessary credit checks or collect or report debts owed to CCII.
• To protect CCII's rights or property; or
• Upon reasonable request by a mutual fund or relating to other investments in customers' account.

CCII does not sell its customers' or prospective customers' personal information. CCII will protect the confidentiality of its customers' personal information. CCII's corporate policies require that employees, with access to confidential information on customers and prospects, may not use or disclose such information except for business purposes. All employees are required to safeguard such information.

CCII will continue to improve its efforts to protect customers' personal information and to make every effort to keep such information accurate and current. In the event that a customer identifies any errors in his or her personal information or wishes to change such information, the customer should promptly request CCII to correct and update its records.