SAFEGUARDING YOUR PRIVACY - CONSUMER NOTICE

For Convergent Capital Management and CCM Family Advisors

This Privacy Policy is effective as of September 1, 2009.

Introduction

All of us at Convergent Capital Management and CCM Family Advisors (together, "CCM") are committed to safeguarding the confidentiality and privacy of the information we maintain on all our clients. This notice describes how we manage and safeguard information about you, our individual client, who seeks or obtains financial products or services from us primarily for personal, family or household purposes. It covers how we protect the information which we have about our current and former individual clients.

Unless you instruct us not to do so, this Privacy Policy permits CCM to very selectively and confidentially share appropriate information with our affiliated companies if we believe there is a resource that may be of interest to you. We never do this for the purposes of broad scale marketing from our affiliated companies and every affiliate is committed to protecting your privacy.

Our Commitment to Safeguarding Your Privacy

CCM does not share any client information with nonaffiliated third parties for marketing purposes.

We never sell any client information to anyone for any reason.

Consistent with our Privacy Policy, CCM may share information they have about you with its affiliates for marketing purposes. We may also share information, for example, when you expressly request that we provide you with certain products and services which are available through one of our affiliates. This helps us make available to you the full range of financial solutions offered through one of our affiliated companies.

If you prefer that CCM not share information about you with others within our affiliates for marketing or other purposes you may tell us not to do so and "OPT-OUT" as provided below.  If you elect to Opt-Out, CCM will not share your information with our affiliated companies except as required or permitted by law.

We will respect your choice even if you end your relationship with us for any reason.

Information We Collect

In the process of serving you, we may collect and maintain the following kinds of client information:

1. Name, address, Social Security number (SSN), income and other client information you provide to us on applications or other forms, in writing, electronically or verbally.
2. Account balances or payment history and other client information about your transactions and holdings that you share with us.
3. The information listed in the bullet points above for businesses, foundations, trusts or other accounts related to your overall financial situation.

Managing Your Information Within CCM Affiliates

We can better provide our service to you if we can share the information we collect about you among our affiliates. We may disclose to these companies all the information we collect about you, except when prohibited by law. However, we limit the availability of that information within the companies to authorized persons who need the information to provide services to you and tell you more about them. See Protecting Your Privacy.

Managing Your Information With Our Vendors and Other Third Parties

To effectively administer and service our daily operations, we use non-affiliated outside vendors to provide some services to our clients. We need to share client information with these vendors to do this work. Each vendor is required to maintain the confidentiality of your information and use that information only to provide the intended service, such as data collection and analysis. We disclose your information to these vendors to establish, administer and manage your account relationships with us.

As permitted or required by law, we may provide client information in response to subpoenas or other legal processes for regulatory and administrative requests and to government agencies in connection with suspicious or criminal transactions, including suspicion of elder or dependent adult financial abuse. These agencies and parties may have their own separate obligations to maintain the confidentiality of your information.

Protecting Your Privacy

We take great care to protect the confidentiality and integrity of the information we maintain about you and our other clients. We regularly validate our information security measures and procedures through independent audits and we monitor the security standards of our outside vendors. We limit the availability of client information to those authorized persons who need access to it to perform their job responsibilities and our employees are required to adhere to our Code of Conduct, which states our expectations to protect the confidentiality of your information.

We have designed our systems to ensure any access codes are private and confidential. We will never ask for client access and account information through e-mail. Therefore, do not respond to any e-mail message asking for authentication information such as passwords PIN numbers, account number, Social Security Number, Taxpayer Identification Number or other such information.

We will notify you about our Privacy Policy when you open an account and every year that you are a client. We will also notify you in the event that we change or modify our privacy policy.

How to Opt-Out

As stated, our Privacy Policy permits CCM to share information about you for marketing and client service purposes with their affiliates unless you instruct us otherwise. You may tell us you want to Opt-Out from this information sharing or request a listing of affiliates by calling us at 626-564-2929 or writing us at Convergent Capital Management, 190 S. LaSalle St., Chicago, IL 60603. A list of affiliates is also available on-line at www.cnb.com/aboutus/terms/affiliate-list.asp.

YOU DO NOT NEED TO CONTACT US UNLESS YOU WANT TO OPT-OUT. If you do Opt-Out and then change your mind, you may contact us to change your preference.

Amendments and Other Law

We reserve the right to alter or amend this Notice and any of the policies or procedures described above at any time. Terms used in this Notice have the meaning given in Title V – "Privacy" of the Gramm-Leach-Bliley Act (Public Law 106-102, codified at 15 U.S.C. 6801 et seq.) or the regulations prescribed under that Act. You may have other privacy protections under state law. To the extent the state law applies, we will comply with regard to our information practices.