PRIVACY OF CONSUMER INFORMATION (REGULATION S-P)

FIVE MILE RIVER INVESTMENT MANAGEMENT, LLC (FMR)

This regulation requires financial institutions to notify clients as to the disclosure of nonpublic personal information.  At Five Mile River Investment Management, LLC all client information is confidential.  The only confidential information that is disclosed is the information that is provided to RBC Advisor Services, a division of RBC Capital Markets, LLC, member NYSE/FINRA/SIPC (RBC) in order to open accounts at Five Mile River or during the yearly audit of RCP; and to determine margin, tax status etc.

Required client information:

·         The personal information that is collected is required by RBC to open accounts; and is information that is mandated to meet the regulatory requirements of the SEC and the State Securities Departments.

·         We do maintain and collect information necessary to manage and administer client’s accounts such as: investment objectives, account balances and historical transactions. This information is also kept confidential.

Client information is kept confidential:

·         Client information is not disclosed or provided to any entity or third party.  Clients can request that a third party, including but not limited to accountants, or other individuals, may receive client information or have on-line access to RBC accounts. 

·         We do not sell client information to anyone.

Our commitment to safeguard client information:

·         We do not present or use client information on the Five Mile website www.fivemileriver.com.  The Five Mile River website (www.fivemileriver.com) does not require a password.

·         We restrict access to client information to employees of FMR.  Employees are required to safeguard total confidentiality regarding client information.

·         We make an ongoing effort to safeguard client information by restricting access to our physical premises and shredding any documents containing client or account information.  Electronic files are secured by passwords.  The backup of data files uses advanced data encryption techniques.

We will provide clients with timely notice of any changes in our privacy practices or those of RBC.

FOR MORE INFORMATION ABOUT TRCM, RCP AND FMR PRIVACY POLICIES, PLEASE CALL US AT 203-388-4848