Privacy Policy Statement

Our firm is obliged by the provisions of the Gramm-Leach-Bliley Act ("Financial Modernization Act of 1999") to notify you regarding our firm's policies and procedures to ensure the confidentiality of non-public, personal information that you provide to us.

"Section 501: it is 'the policy of Congress that each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers' nonpublic personal information.' "Non-public personal information" means personally identifiable financial information and any list, description, or other grouping of consumers derived from any personally identifiable financial information that is not publicly available.

We may obtain nonpublic personal information about you from these sources:

Maintaining the safety, confidentiality, and integrity of your records has always been part of the service provided by RAS. Access to our office records containing information about you is restricted to the firm's officers, your advisory representative and systems personnel in the normal course of business, and to authorized personnel at Penson. The office is secure and computers or other records are not readily available to any other persons.

To Whom Do We Disclose Information:

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by that person, or permitted or required by law.

Generally, information gathered about you from any source is provided only to other parties whose services you expressly have requested, and only as you have authorized with your signature on documents allowing that information to be shared. Those parties, specifically, are the agents and parties with whom RAS has arrangements to effect client transactions, and may include insurance companies, professional money managers, and securities agents such as those associated with AssetMark investment programs.

To other companies as necessary to process your business. For example, we process your investment instructions through product and service providers with whom we have business agreements. The information that we obtained from you is given to the product and service providers for purposes of effecting transactions in your account and preparing your account statements. These parties must limit their use of the information to the purpose for which it was provided (for example, your signed release to an insurance company to check with a credit rating bureau).

Where required by law or regulation. For example - responses to a subpoena, court order or regulatory demand.

As authorized by you . You may direct us, for example, to send account statements or other account information to a third party.

As otherwise authorized or permitted by law. For example, the law permits us to respond to a request for information about you from a consumer-reporting agency. (Normally, such requests also include a release form signed by you.)

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