Privacy/Disclaimer

Disclaimer

SOL Capital Management Company (SOL) is an SEC registered investment advisor located in Rockville, Maryland. SOL is in compliance with the current registration and/or notice filing requirements imposed upon SEC registered investment advisors by those states in which it maintains clients. SOL may only transact business in those states in which it is registered, or qualify for an exemption or exclusion from registration requirements. The SOL website is limited to the dissemination of general information pertaining to SOL's investment advisory services. Accordingly, SOL does not, and will not, effect or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication with a prospective client shall be conducted by a representative of SOL who is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.

Privacy Policy

Dear Client:

As you may know, the U.S. Securities and Exchange Commission has adopted Regulation S‐P, “Privacy of Consumer Financial Information,” which applies to, among other things, brokers, dealers, investment companies and registered investment advisers. Generally speaking, Regulation S‐P requires that these entities limit their use of certain non‐public personal information they may learn about you, such as your name, occupation and financial history. In addition, state laws may further limit these entities’ use of such information. As a registered investment adviser, SOL Capital Management Company (SOL) is required to provide our clients with an annual notice describing our privacy policies and practices. The policies described below apply both to current clients and to individuals who no longer have a relationship with SOL.

Information We Collect. In order to provide our services to you we collect non‐public personal information about you from the following sources: (1) information we receive from you on brokerage account applications, investment advisory contracts or other forms or that you otherwise provide, such as your name, birth date, telephone number, social security number, tax identification number, bank account information, address and income; (2) information about transactions in accounts managed by SOL, such as your trading history and account balance; (3) information we may receive from non‐affiliated third parties; and (4) through the use of session “cookies” that record encrypted authentication information, but which expire when you log out of our website or close your web browser.

How We Use This Information. In general, the information we collect is used for the purpose of providing you with the services you have requested in the manner you have requested them. For example, you may request that SOL post your account information in the password‐protected area of our website for you to view at your leisure. If you have not requested this specifically, it is not posted there for you. While we may use the information we collect for purposes of marketing our services to you, we do not sell or rent any information about you, including any non‐public personal information, or any information collected during your use of the password‐protected area of our website. We have no intention of doing this in the future. Nor do we share your non‐public personal information with non‐affiliated companies so that they may market their products or services to you or engage in joint marketing with us. We have no intention of doing this in the future.

Who Has Access To This Information? We make no disclosure of any non‐public personal information we collect to any non‐affiliated third parties other than to government regulatory agencies or as otherwise permitted or required by law. We limit access to non‐public personal information to individuals in our organization who need it in order to perform their jobs, and to non‐affiliated third parties who provide services you request. For instance, we may provide some non‐public personal information to service providers so that we (and the service providers) can provide services to you. As one example, non‐public personal information that we collect from you and your transactions with us or non‐affiliated third parties is shared with financial services providers, such as the custodians that handle the securities custody and trading for your portfolio(s). Our employees and these service providers are contractually prohibited from disclosing or using this information for any purpose other than that for which it was disclosed. We also may disclose your non‐public personal information when we believe such disclosure is required to comply with a legal requirement, such as in response to a court order, subpoena or in the course of a legal proceeding. We may also disclose personal information as otherwise permitted by applicable law.

Business Transfers. If there is a change of control in SOL’s business (whether by merger, sale, or otherwise), our client information could be sold as part of that transaction and your non‐public personal information could potentially be used by the purchaser. However, if the purchaser materially changes this privacy statement or the information‐handling practices described herein, such changes will be described to you and you will have the ability to opt‐out of any proposed changes in the way your non‐public information will be used, if such opt‐ out right is required under the law.

How We Protect Your Information. At SOL, the security and confidentiality of our clients’ non‐public personal information is carefully guarded. We restrict access to non‐public personal information about you to those service providers, or employees of SOL who need to know that information in order to provide products or services to you. SOL does not construct or sell any list, description or other grouping of our clients’ non‐public personal information derived from information that is not publicly available. We have no intention of doing so in the future.

In order to protect your non‐public personal information, we maintain physical, electronic and procedural safeguards that comply with applicable standards. Your account information and profile are password‐ protected. We monitor for intrusion attempts, conduct security audits and inspections, and use firewalls and SSL (Secure Socket Layer) data and password encryption technology. Notwithstanding these security measures that we use to help protect your non‐public personal information, no electronic data transmission or storage of information can be guaranteed to be secure. Please note that we cannot ensure or warrant the security of any information you provide to us.

How to Help Protect Your Information. Because you, too, play a role in protecting your non‐public personal information, we recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited e‐mail. When using the password‐ protected area of our web site, remember to sign out of your account and close your browser window when you have finished your service. This is to help ensure that others cannot access your non‐public personal information if you share a computer with someone else or are using a computer in a public place where others may have access to it.

Changes. We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you prior to the change becoming effective.

Your Right to Review Your Information. You may, if you wish, request that we send you a summary of the information we have collected about you, and you may seek correction of information you believe to be inaccurate.

Please be assured that we at SOL are committed to protecting the privacy and confidentiality of your non‐ public personal information. If you have questions about this notice or about how your confidentiality is being protected, please do not hesitate to call us at (301) 881‐3727.

Sincerely,
SOL Capital Management Company