UMBFS Privacy Statement

UMB Fund Services, Inc., including its wholly owned subsidiary JD Clark & Company (collectively referred to as “UMBFS”), is mindful of its clients’ privacy obligations under Regulation S-P. Accordingly, pursuant to its transfer agency or investor recordkeeping agreements with its clients, UMBFS keeps all records and other information relative to investors confidential, and will not use this information other than for purposes of fulfilling its transfer agent or investor recordkeeping duties, except when requested to divulge such information by duly constituted authorities or court process, or when requested by an investor or an investor’s agent. In addition, UMBFS reviews the confidentiality provisions of its contracts with all vendors who have access to any investor information during the performance of their duties. Where confidentiality provisions are not sufficient to meet the standards of Regulation S-P, such contracts are revised or, alternatively, the vendor enters into a separate Regulation S-P privacy amendment. 

As a wholly owned subsidiary of UMB Financial Corporation, UMBFS is covered by its parent corporation’s privacy policy to the extent applicable to its operations. In addition, UMBFS has adopted separate policies under applicable federal and state law on the disposal of documents and other materials containing certain specified financial and consumer credit information. Documents covered by the policies are shredded and/or disposed of in accordance with Federal and state law.

UMBFS restricts access to nonpublic personal information about investors to those employees who need to know the information in order to provide products and services to its fund clients and their investors. UMBFS maintains physical, electronic and procedural safeguards that comply with federal standards to guard investors’ nonpublic personal information.