Privacy and Security of Consumer Financial Information

In order to assist our customers in meeting the requirements of the Gramm-Leach-Bliley Financial Modernization Act (the “GLBA”), THE BAKER GROUP LP hereby sets out in writing our policy and practices regarding the privacy of information provided by our customers and their consumers. Until amended or superseded, this Policy constitutes our contractual commitment to our financial institution customers as follows:

THE BAKER GROUP LP will not disclose, nor permit access to, the private information of a financial institution customer or its consumers for any purposes other than those specifically required to fulfill THE BAKER GROUP LP contractual obligations with its financial institution customers. THE BAKER GROUP LP will not sell the information regarding a financial institution’s consumers for any reason.

In connection with the provision of services to financial institution customers, THE BAKER GROUP LP will take all commercially reasonable steps to ensure the security and confidentiality of customer and its consumer information and to protect against anticipated threats and hazards to the security of such information. THE BAKER GROUP LP will take all commercially reasonable steps to prevent unauthorized access to or use of such information that would result in substantial harm or inconvenience to any customer or its consumers.

In the event any court or regulatory agency seeks to compel disclosure of said information THE BAKER GROUP LP will, if legally permissible, promptly notify its financial institution customer of said attempt and will cooperate so that its financial institution customer may at its expense seek to legally prevent this disclosure of information.

With respect to our systems, THE BAKER GROUP LP will upon request provide copies of applicable audit reports, summaries of test results and other equivalent evaluations with regard to security and confidentiality in connection with the services THE BAKER GROUP LP provides to that customer. THE BAKER GROUP LP may charge a standardized fee to respond to such requests.

If a breach in security results in an unauthorized intrusion into THE BAKER GROUP LP systems which directly and materially affects a financial institution customer of THE BAKER GROUP LP or its customers, THE BAKER GROUP LP will within a reasonable time report on the intrusion and the information compromised to the affected financial institution, and will subsequently report the corrective action taken in response.

BY: Misty Wrinkle
Chief Compliance Officer