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Bridging the Border to Your Financial Future

Privacy Notice

Keats, Connelly and Associates, LLC ("Keats Connelly"), and its wholly-owned subsidiary, Cross Border Tax & Accounting, LLC ("CBTA"), maintain physical, electronic, and procedural safeguards that comply with federal standards to protect our clients' nonpublic personal information ("information"). Through this policy and our underlying procedures, Keats Connelly and CBTA attempt to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of Keats Connelly and CBTA to restrict access to all current and former clients' information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. Keats Connelly and CBTA may disclose a client's information if Keats Connelly or CBTA is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with Keats Connelly or CBTA, including, but not limited to the client's other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Keats Connelly or CBTA in order to facilitate the commencement /continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by a client for Keats Connelly or CBTA (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

Keats Connelly and CBTA permit only authorized employees and affiliates who have signed a copy of the Keats Connelly/CBTA Privacy Policy to have access to client information. Employees violating the Keats Connelly and CBTA Privacy Policy will be subject to Keats Connelly's or CBTA's disciplinary process. Additionally, whenever Keats Connelly or CBTA hire other organizations to provide services to Keats Connelly or CBTA for clients, Keats Connelly or CBTA will require them to sign confidentiality agreements and/or the Privacy Policy.

Should you have any questions regarding the above, please contact Dale A. Walters, CEO and Chief Compliance Officer, of Keats Connelly, at (602) 955-5007.

(3/2007)