Your Privacy is Important to Us

At Sanders Morris Harris we recognize the importance of protecting your privacy. We strive to maintain the privacy of your personal nonpublic information while we help you achieve your financial objectives. The following disclosure explains what nonpublic personal information we collect about you, why we collect it, what we do with that information, and the steps we have put in place to protect the nonpublic personal information you have entrusted to us.

Information We Collect

To serve you better and to manage our business, it is important that we collect and maintain accurate information about you. We collect nonpublic personal information about you, including, your name, address, social security number, and financial information, from the following sources:

• From you on the telephone, in person, or through mail;
• From you on applications or other forms you complete;
• Through transactions in your accounts with us, our affiliates, or others;
• From our internet website; and
• From third parties with whom we deal, such as a consumer reporting agency, to verify information we receive from you and your creditworthiness.

Protecting Your Information

We restrict access to your nonpublic personal information to those employees and agents who need access to the information to perform their job functions or provide products or services to you. We protect your nonpublic personal information from access by third parties by maintaining physical, electronic, and procedural safeguards. We strive to ensure the protection of client personal information from receipt through destruction.

Information We Disclose to Third Parties

We do not disclose any of your nonpublic personal information to non-affiliated third parties without your consent except as required or permitted by law or unless those parties are providing services or support to us and have agreed to keep your nonpublic personal information confidential. Examples of these parties include the companies or individuals we use to (a) execute and clear our securities transactions, (b) prepare and mail your account statements, (c) help us verify information, including identity, (d) provide us with consulting, legal, and accounting services, (e) help us develop, operate, and maintain our services and systems, and (f) provide services and products to you, such as mutual fund companies, investment management program sponsors, investment managers and advisers, and insurance companies. Even if you cease to transact business with us, we will continue to apply the same protections to your nonpublic personal information as we did when you were an active client.

The Sanders Morris Harris Group

The Sanders Morris Harris Group is a family of related companies that are owned in whole or in part by Sanders Morris Harris Group Inc. (Nasdaq: SMHG). These affiliated companies allow us to provide greater value to our customers, employees, and shareholders. To provide you with the products and services you request, to serve you better, to manage our business, and as otherwise permitted or required by law, we may disclose personal information we collect about you to other Sanders Morris Harris Group companies. All of our affiliates follow the same privacy policies.

Changes to Our Privacy Policy

We maintain a public internet site at www.smhgroup.com. While this policy is delivered annually in writing, the policy may change from time to time. We will notify you of any changes. You can always review our current policy, and the names of the Sanders Morris Harris Group companies to which the policy applies, online.

Following is a list of the Sanders Morris Harris Group companies to which this notice applies, as of December 1, 2008:

• Concept Capital, a division of SMH Capital Inc.
• Cummer/Moyers Capital Advisors
• Cummer/Moyers Financial Services
• HWG Insurance Agency
• Kissinger Financial Services
• Leonetti & Associates, LLC
• Miller-Green Financial Services, Inc.
• Sanders Morris Harris
• Sanders Morris Harris Group Inc.
• Signet Healthcare Partners, LLC
• SMH Asset & Wealth Management
• SMH Capital Inc.
• SMH Capital Advisors, Inc.
• SMH Partners
• SOF Management, LLC
• The Dickenson Group, LLC
• The Rikoon Group, LLC