NOTICE OF PRIVACY POLICY

SEC regulations require that we provide individual clients with a notice of our Privacy Policy at the beginning of our business relationship and annually thereafter. For prospective individual clients, we are required to provide a Privacy Policy notice, if we collect any personal nonpublic information.

At Carmel Capital Management L.L.C. (CCM), we respect your right to privacy. We understand that the privacy and security of your nonpublic personal information is important to you and we maintain safeguards designed to protect your data from unauthorized access. (For individuals residing in California, we are required to notify you of any unauthorized access to your nonpublic information which we keep in an unencrypted format on our computers.) We do not share the information we collect about our clients or former clients with any unaffiliated third parties, except as required for the purpose of serving your investment needs or required by law. This means we may disclose the information we collect to our affiliates and to the unaffiliated third parties that help us maintain and service your account. For example, we may share information with a transfer agent or clearing broker to process your securities transactions and update your account or to an external service provider so that your account statements can be printed and mailed. These unaffiliated third parties are only permitted to use this information for the services for which we hired them, and are not permitted to use or share this information for any other purpose. We may also disclose nonpublic personal information when the firm 1) receives your prior written consent or instructions,; 2) believes that the recipient is your representative who has been authorized by you to receive such information; or 3) is required by law to disclose such information to government agencies and regulatory organizations. For example, we may be required by the USA PATRIOTS Act to disclose information related to suspected money-laundering activities. Clients consent to disclosure of their identity as a client of the firm.

If you decide to close your account(s) or become an inactive customer, CCM will adhere to the privacy policies and practices as described in this notice. If your portfolio is held through a financial intermediary, such as a broker-dealer, bank or trust company, the privacy policy of your financial intermediary will govern how the intermediary will handle your nonpublic personal information and whether it will be shared with other parties.