USA Patriot Act
ACCOUNT OPENING PROCEDURES AND CUSTOMER IDENTIFICATION NOTICE

To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions to obtain, verify, and record information that identifies each individual or institution that opens an account or establishes a customer relationship with M. R. Beal & Company.

This means that when you open an account, we will ask you for certain information relating to your identity including your name and address. U.S. citizens will need to provide a social security number, and U.S. institutions will need to provide a tax identification number. Non-U.S. citizens will need to provide a passport or other government-issued photo identification document. Foreign entities must provide a tax identification number.

M. R. Beal & Company, together with our clearing agent, will screen the information provided by you against various databases to verify your identity. In addition, customers may be asked to provide certain identification documents, as necessary, to enable the firm to verify your identity.

M. R. Beal & Company is required to verify the identity of its customers. If all required documentation or information is not provided or we are unable to verify your identity, M. R. Beal & Company may be unable to open an account or establish a relationship with you, or the firm may have to restrict trading or close an existing account.

BUSINESS CONTINUITY NOTICE
M. R. Beal & Company has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (212) 983-3930, you should call our alternative number 800-451-9702 or go to our web site at www.mrbeal.com. If you cannot access us through either of those means, you should contact our clearing firm, Pershing, LLC, at 201-413-3635. At that number, you will hear recorded instructions on how you can access your account, access your funds and securities, place orders and process other types of transactions. Customers can fax written requests to Pershing at 201-413-5368. If you cannot contact Pershing at the previously noted telephone number, Pershing can also be contacted at 201-624-6100, ext. 500 as an alternate phone number. Additional information about Pershing can also be found on their website at www.pershing.com.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, Pershing, backs up our important records in a geographically separate location. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 4 hours. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to another local M. R. Beal office, a business resumption facility provided by our clearing firm, or another local site when needed. In such case we expect to recover and resume business within 4 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and use our best efforts to recover and resume business within 24 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.mrbeal.com about how to contact us. Our response to a disruption relies on other organizations and systems, especially those of our clearing firm, Pershing. This reliance will be even more important in the event of a significant external business disruption such as a terrorist attack or citywide disaster. If the significant business disruption is so severe you are unable to contact us or that it prevents us from remaining in business, you should contact our clearing firm Pershing at 201-413-3635 to receive instructions on how to access your and account and the securities and funds contained in your account.

For more information – If you have questions about our business continuity planning, you can contact our Compliance Department at 212-983-3930.

PRIVACY NOTICE
This Privacy Policy describes how M. R. Beal & Company collects and protects your information. We consider customer privacy to be fundamental to the relationship with our clients. M. R. Beal is committed to maintaining the confidentiality, integrity and security of all personal and confidential information that we may have regarding clients. M. R. Beal does not sell personal information about its clients to anyone. We collect information from you that is required to transact business or which may be required to fulfill legal and regulatory requirements. From time to time, we may request additional information to help us further serve your needs and preferences.

The personal information we collect directly from you includes information required to (i) communicate with you, such as your name, mailing address, telephone number and e-mail address, and (ii) verify your identity, such as your address and tax identification number. You directly provide us the majority of information we collect. You do this by providing information at the time you open your account and providing related documentation. Other ways we obtain information are by providing services to or transacting business with you, by sending us an e-mail, by visiting our website and through other sources such as information services and consumer reporting agencies, affiliates and business partners.

We restrict access to personal information to those who require it to provide services to you. M. R. Beal employees and agents are instructed and required to safeguard and keep confidential personal information of our clients. In the course of conducting business, we may disclose some or all of the previously described information to our clearing firm and other businesses including non-affiliated third parties, as allowed by law for purposes of: providing services or account maintenance; in response to a subpoena, to prevent fraud, or to comply with an inquiry by a government agency or regulator; and to perform services for our firm or on behalf of our firm.