Disclosures

RBP INVESTMENT ADVISORS INC.

PRIVACY POLICIES AND PROCEDURES

This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand the privacy policies and procedures that we have implemented to safeguard your nonpublic personal information.

INFORMATION WE COLLECT

RBP Investment Advisors Inc. (RBPIA) must collect certain personally identifiable financial information about its customers to ensure that it offers the highest quality financial services and products. The personally identifiable financial information that we gather during the normal course of doing business with you may include:

  1. Information we receive from you on applications or other forms;
  2. Information about your transactions with us, our affiliates, or others;
  3. Information collected through an Internet “cookie” (an information collecting device from a web server); and
  4. Information we receive from a consumer reporting agency.

INFORMATION WE DISCLOSE

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. In accordance with Section 248.13 of Regulation S-P, we may disclose all of the information we collect, as described above, to certain nonaffiliated third parties such as attorneys, accountants, separate account managers and persons or entities that are assessing our compliance with industry standards. We may also share certain information from time-to-time with other entities that are also engaged in financial services (e.g., Charles Schwab, TD Waterhouse or SEI). Sharing such information among these firms enables us to maximize the services we can offer; creating, in effect, a financial services supermarket with a wide range of products under one roof. We enter into contractual agreements with all nonaffiliated third parties that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.

We do not provide or disclose any nonpublic information to non-affiliated third parties for marketing purposes. We also do not sell or share lists of active or inactive customers.

CONFIDENTIALITY AND SECURITY

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide financial products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

If you have any questions or concerns regarding the RBPIA Privacy Policy or any other matter, please call us at (888) 806-0604, and ask for Richard Pear or Peter Landini.

Disclaimer

The information that is provided on RBPIA web pages has been compiled to the best of our ability. However, the authors of these documents make no warranty of any kind, expressed or implied, and will not be held responsible, or liable for errors, or omissions resulting in any loss or damage caused or alleged to be caused, directly, or indirectly, by information contained in RBP Investment Advisors Inc. publications.

Links to other web sites are provided as general information sources for use of visitors to our site. RBPIA has not formally evaluated the information provided via these sites and inclusion of these links does not constitute an endorsement of any organization. The links provided are maintained by their respective organizations and they are solely responsible for their content. Trademarks are the property of their respective owners

Copyright

Absolutely none of the artwork, pictures, and/or informational text may be used, whether in standard or modified format, by any individual and/or company engaged in the business of financial planning without the express written permission of RBPIA. Your viewing of this document is your acceptance of these terms.

All web pages are intellectual property of RBPIA and are protected by copyright laws. All copyrights for RBPIA web presence are owned by RBPIA with all rights reserved. Any individual is allowed to view, print, and link to these pages provided they observe the following:

The documents and images can only be used for non-commercial purposes.

Our documents may not be associated with anything which is illegal, unethical or immoral. Our documents may only be used for information purposes.

Compliance

NASD Conduct Rule 2280. Investor Education and Protection

(a) Each member shall, with a frequency of not less than once every calendar year,provide in writing to each customer the following items of information.

(1) NASD Regulation Public Disclosure Program Hotline Number

(2) NASD Regulation Web Site Address

(3) A statement as to the availability to the customer of an investor brochure that includes information describing the Public Disclosure Program

(b) Notwithstanding the requirement in paragraph (a) above, any member that does not carry customer accounts and does not hold customer funds or securities is exempt from the provisions of this rule.

© 1997, National Association of Securities Dealers, Inc. (NASD). All rights reserved.

RBP Investment Advisors Inc. is a U.S. Securities and Exchange Commission (SEC) Registered Investment Advisor (RIA). RBPIA and its Principals are in compliance with the current registration and/or notice filing requirements imposed upon SEC-registered investment advisers by those states in which RBP maintains clients. RBPIA may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. Further written detailed disclosure information contained in Form ADV Part I and II is available upon written request.

You cannot conduct business with RBPIA over the Internet nor should you view the information contained herein as an offer for the services of any Principal with RBPIA. RBPIA does not render nor offer to render personalized financial planning or investment advice through this medium.

All references made to investment or portfolio performance are based on historical data and past performance should never be viewed as a guarantee of future results. In addition, RBPIA does not make any representations or warranties as to the accuracy, completeness, or relevance of any information prepared by any unaffiliated third party provider, whether linked to RBPIA's web site or incorporated herein. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Protecting Clients Privacy

Gramm-Leach-Bliley (GLB) Act

Disclosure of Nonpublic, Personal Information

Congress passed legislation in 2000 to modernize the laws governing the financial services industry. Included were several provisions to enhance the customer privacy protections that have been the hallmarks of securities firms, banks and insurance companies.

All financial institutions, including RBP Investment Advisors Inc. (RPBIA) must clearly, conspicuously and annually disclose their policies for collecting and sharing nonpublic, personal information. Specifically, these policies must disclose:

· The categories of nonpublic, personal information that are collected;

· The kinds of nonpublic, personal information disclosed to affiliates and third parties, and the categories of persons who receive such information;

· How nonpublic, personal information of former customers is shared; and

· Procedures to protect the security and confidentiality of nonpublic, personal information.

Collection of Information

RBPIA collects information from you in accordance with industry standards and regulatory requirements. The categories of nonpublic personal information that we collect from a client depend upon the scope of the client engagement. Such information usually includes your name, how you want your account established, your address, social security number, telephone number, employer information, tax bracket and related information, income and net worth figures, including detail of your investments and other assets, your investment history, investment objectives, risk preferences, marital status and other personal information. Without such information, we could not work with you.

We obtain this information from you from your initial advisory agreement or account application, investment statements, tax returns, questionnaires and other background material. Most of this information is transferred into our computer system.

Disclosure of Information

The information in our computers and our files is available to all RBPIA employees, each of whom has signed a confidentiality agreement with the firm. We may also share certain information from time-to-time with other entities that are also engaged in financial services (e.g., Charles Schwab or SEI). Sharing such information among these firms enables us to maximize the services we can offer creating, in effect, a consolidated package of services with a wide range of products under one roof. We may also from time to time share information about you with certain unaffiliated third parties with whom we must interact in order to conduct business on your behalf. These third parties may include the custodians of assets held in your account(s), separate account money managers, lawyers or accountants. We would, in virtually ever instance, solicit your approval before disclosing personal information to such third parties. Federal and state regulators also may review our firm records as permitted under law.

We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.

"Opt-Out" Right

The new laws require that we give you the means to prevent the transfer of any nonpublic, personal information to a non-affiliated third party before the information is disclosed. By so doing, you would also be able to prevent such third parties from re-disclosing such information.

Your right to "opt-out" from our disclosure of your nonpublic, personal information does not apply where such information must be shared to produce a consolidated statement, to complete a transaction, or to service your account. Your right to "opt-out" also does not apply to information which we may disclose to market our own products and services, as well as the products and services which we may offer through joint agreements with other financial institutions.

Please contact us at 888-806-0604 to request a form by which you may exercise your option to "opt-out" from our disclosure of your nonpublic, personal information (with the exceptions noted above).

Security and Confidentiality Safeguards

At RBPIA, we have established strong measures to ensure the security and confidentiality of customer information. Our computer database has security measures to protect against threats or hazards to the security and/or integrity of customer records, and protect against unauthorized access to records that may harm or inconvenience our customers. In addition, we fingerprint all newly hired employees who have access to client information and forward the fingerprint cards to the National Association of Securities Dealers (NASD).

Former Customers

If you discontinue using RBPIA's services, we retire your account information. We consider your account closed once your last account position has been transferred away from us. From that closure date, we maintain your records for at least three years (but generally no more than six years).

RBPIA's Principal have a long-established tradition of discretion and respect for our clients' personal privacy. We reinforce this in the way we routinely handle sensitive client information as part of our day-to-day operations. We believe this contributes to the trust and confidence our clients have placed in us. We will continue to do what we have always done; putting our clients first with the highest respect for their privacy.

Sincerely,

RBP Investment Advisors Inc.