Privacy Disclosure

Pursuant to federal regulations Lombard Securities Incorporated ("LSI") has established the following policies with respect to the disclosure of nonpublic, personal information obtained in connection with your opening and maintaining an account with LSI:

(i) Any information disclosed on a Customer Account Application Agreement, Margin Agreement, Option Account Application, IRA Application, Form 151, or any other papers required, or requested, in connection with the opening of an account with LSI, and any periodic statements of account activity, and trade confirmations, are covered by these policies.

(ii) Such information may be disclosed to administrative and operational employees of LSI for the purposes of permitting them to service your accounts and process your transactions, as well as to your registered representative and his/her administrative staff.

(iii) Such information may be disclosed to any of LSI's affiliates, including Lombard Agency, Inc., and Lombard Advisers Incorporated.

(iv) Such information will be disclosed to LSI's correspondent, Penson Financial Services, Inc. ("Penson Financial"), and to the money market fund provider in connection with your opening a money market sweep account, or to a non-affiliated investment adviser providing WRAP account services, and members of their staffs, for the purpose of servicing your account.

(v) Such information, including account numbers, shall not be disclosed by LSI to other non-affiliates of LSI, except under the foregoing circumstances:

        (A) Upon the receipt of written request or authorization to do so, signed by you, the
        customer(s); or,

        (B) In connection with an examination of LSI's books and records by a regulatory
        organization established under federal or state laws; or,

        (C) Pursuant to a subpoena issued by a court or arbitration of competent
        jurisdiction; or,

        (D) In connection with the submission of an application, signed by you, to
        purchase an insurance product or mutual fund product.

(vi) Such information shall be maintained in both hard-copy and electronic format, and shall be accessible to the staff members of LSI, your registered representative, and to staff members of Penson Financial , and our money market provider, or their agents. Hard copy documents are not available to non-associated persons, and electronic format is secured by firewalls requiring authorized password(s) to access.

(vii) Opt Out Provisions: You do have the right to prevent the disclosure of non-public personal information to non affiliated third parties - commonly referred to as the right to "opt out". However, this opt out provision does not apply in cases where the information sharing is necessary to provide consolidated statements of account activity, complete a transaction, or service your account, nor does it apply to information disclosed to market products or services offered through joint agreements with another financial institution, e.g., Penson Financial, our money market fund provider, and investment advisers with whom Lombard Advisers Incorporated has WRAP fee arrangements. Should you not wish disclosures be made to any of the foregoing financial institutions, or to affiliates of LSI, or, should you be unable to accept any of the disclosure exceptions specified in Section (v) above, you must notify the firm's Customer Service Department immediately, so that your account may be closed in that LSI would not be able to service your account under such circumstances.

Lombard Securities Incorporated Customer Service
410.342.1300
800.755.2144
Fax: 410.732.0303
Penson Financial Services, Inc.
214.765.1009