Important Notice Concerning Privacy of your Personal Information

As has always been our policy, Tower Asset Management does not share your personal information with vendors or services not directly related to your account without your permission.
1 Tower collects nonpublic personal information about you to open your account(s), to process your transactions and to help us provide a better level of service. Information is gathered from the following sources:

   * Information we received from you on applications, agreements or other forms;
   * Information about your transactions with us or others

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

We restrict access to your personal and account information to those employees or entities2 who need to know that information to provide products or services to you. We provide physical, electronic, and procedural safeguards to guard your nonpublic personal information.

[1] Services directly related to your account would include the brokerage account where your account is held and proxy service providers.

[2] We may provide your information to third parties upon your written request or, if required, to complete the purchase of a particular product managed by another entity. These products would include mutual funds. The information provided may include your name, address, social security number, dividend payment instructions, age, and financial information. These companies have privacy policies which may be requested from those entities.