POCHOP FINANCIAL MANAGEMENT, INC.

PRIVACY NOTICE

Your privacy is important to us. While information is the foundation of our business, our most important asset is your trust. We are required by law to (a) provide this notice to you describing our privacy policies and practices, (b) to not disclose any non-public personal information to non-affiliated third parties unless you have a reasonable opportunity to “opt-out”, and (c) to adopt procedures to safeguard your privacy. This notice applies to individuals, not businesses or corporations, and to former clients. It will be provided to you when you open an account, and an annual notice will be distributed to you as part of our annual portfolio review. We maintain physical, electronic, and procedural safeguards that comply with federal standards to protect your non-public personal information (the "Information"). Through this policy and its underlying procedures, we attempt to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

We restrict access to the Information to those employees and non-affiliated entities who need to know the Information in order to provide products or services to you. We may disclose the Information if we have been: (1) previously authorized in writing to disclose the Information to individuals and/or entities not affiliated with us, including, but not limited to your other professional advisors and/or service providers (e.g., attorney, accountant, insurance agent, broker/dealer, investment advisor, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the you for processing and/or transmittal by us in order to facilitate the commencement/continuation/termination of a business relationship between you and a non-affiliated third party service provider (i.e., broker/dealer, investment advisor, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by you for us (e.g., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by you with respect to the corresponding non-affiliated third party service provider.

We permit only authorized employees, who are trained in the proper handling of Information, to have access to that Information. Employees who violate that our privacy policies are subject to our normal disciplinary process. We do not disclose any Information, except to non-affiliate third party companies who provide us services, i.e., custodial brokers, computer service companies, portfolio systems software companies and general administrative service companies, and as permitted by law. We require such companies to agree to secure the privacy of the Information we share with them which is essential to our business. If we otherwise intend to disclose information to persons other than the entities listed above we will notify you in advance and give you an opportunity to “opt-out” of such disclosure. We will promptly notify you of any changes in our privacy policy.

Should you have any questions regarding the above, please contact Rene A. Pochop, President, at (802) 865-4900.

Pochop Financial Management, Inc.
1233 Shelburne Road
Suite 420
Burlington, VT 05403