Protecting Your Privacy

At CPI, protecting our client/owner’s privacy is paramount. We realize financial matters are extremely private and sensitive in nature. The following is our privacy policy and pledge to you. This policy and pledge enables us to protect your privacy while providing you with high quality products and services.

CPI has entered into a management agreement with Sterne Agee Clearing, Inc. Employees of CPI are also dual employees of Sterne Agee Clearing, Inc. or one of its affiliates. Accordingly, we will share information with Sterne Agee Clearing, Inc. and its affiliates* (“Sterne Agee”) to the extent it is necessary.

Information We Collect
We collect only the information that is required to provide you with the highest quality professional services or that is required by law and regulation. We maintain strict security procedures to protect the information that we collect.

We collect nonpublic personal information about you from:

· Applications or other forms we receive from you;

· Transactions with us, our affiliates, or others; and

· Consumer reporting agencies as needed.

Limited Disclosure of Information
We provide non-public personal information (as noted above) to outside vendors only to the extent necessary to complete your financial transactions, keep you fully informed as to these transactions, and maintain our professional relationship with you. Any information that we must provide outside vendors is restricted as to content and recipient. Any organization that receives such information must provide Sterne Agee with a copy of its privacy policy, and each policy will be reviewed to ensure that it is sufficient to meet Sterne Agee’s client information privacy standards. Under no circumstances whatsoever will Sterne Agee or CPI sell information about you or your business to any vendor, public or private.

Confidentiality and Security
Employee access to client information is restricted to those who have a legitimate need to know in order to provide our professional services or to comply with laws and regulations. We maintain both physical and electronic safeguards in accordance with federal law and regulatory standards; any employee who has access to individual information receives training about and is required to follow company procedures designed specifically to keep that information confidential. These procedures are also designed to ensure that your financial information is accurate, current, and complete. Please notify us if at any time our records contain incomplete or inaccurate information about you. Upon notification from you regarding our records, we will promptly address your concerns and make any necessary corrections.

Our policies and practices for the disclosure of information, stated above, apply to both current and former clients of CPI.

*Sterne Agee Group, Inc.; Sterne Agee Asset Management, Inc.; and The Trust Company of Sterne Agee & Leach, Inc. are not registered broker-dealers. Sterne Agee Group’s subsidiaries Sterne Agee & Leach, Inc.; Sterne Agee Clearing, Inc.; and Sterne Agee Financial Services, Inc. are registered broker-dealers and are members of the Securities Investor Protection Corporation (SIPC).