Privacy/Disclaimer

Disclaimer

SOL Capital Management Company (SOL) is an SEC registered investment advisor located in Rockville, Maryland. SOL is in compliance with the current registration and/or notice filing requirements imposed upon SEC registered investment advisors by those states in which it maintains clients. SOL may only transact business in those states in which it is registered, or qualify for an exemption or exclusion from registration requirements. The SOL website is limited to the dissemination of general information pertaining to SOL's investment advisory and financial planning services. Accordingly, SOL does not, and will not, effect or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication with a prospective client shall be conducted by a representative of SOL who is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.

Privacy Policy

Dear Client:

As you may know, the U. S. Securities and Exchange Commission has adopted Regulation S-P, “Privacy of Consumer Financial Information,” which applies to all brokers, dealers, investment companies and registered investment advisers. As a registered investment adviser, SOL Capital Management Company (SOL) is required to provide our clients with an annual notice describing our privacy policies and practices. Depending on your state of residence, state law may provide you with additional protections and may require that we send you additional notices. The policies described below apply both to current clients and to individuals who no longer have a relationship with SOL.

Information We Collect. We collect nonpublic personal information about you from the following sources: (1) information we receive from you on brokerage account applications or other forms, such as your name, address and income; (2) information about your transactions with SOL, such as your trading history and account balance.

How We Use This Information. In general, the information we collect is used for a single purpose--to provide you with the services you have requested in the manner you have requested them. For example, you may request that SOL publish your account information in the password-protected area of our website for you to view at your leisure. If you have not requested this specifically, it is not published there for you. We do not sell or rent personally-identifying information about you, including any information collected during your use of the password-protected area of our website.

Who Has Access To This Information? We make no disclosure of any nonpublic personal information we collect to any non-affiliated third parties other than to government regulatory agencies or as otherwise permitted or required by law. For example, we share information with service providers, such as the custodians that handle securities custody and trading for your portfolio(s).

We restrict access to nonpublic personal information about you to those record-keepers, custodians, or employees of SOL who need to know that information in order to provide products or services to you. SOL does not construct or sell any list, description or other grouping of our clients' nonpublic personal information derived from information that is not publicly available. We have no intention of doing so in the future.

How We Protect Your Information. At SOL, the privacy and confidentiality of our clients' nonpublic personal information is carefully guarded. In order to protect your nonpublic personal information, we maintain physical, electronic and procedural safeguards that comply with federal and state standards.

Your account information and profile are password-protected. Because you, too, play a role in protecting your personal information, we recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. When using the password-protected area of our web site, remember to sign out of your account and close your browser window when you have finished your service. This is to help ensure that others cannot access your personal information if you share a computer with someone else or are using a computer in a public place where others may have access to it.

You may, if you wish, request that we send you a summary of the information we have collected about you, and you may seek correction of information you believe to be inaccurate.

Please be assured that we at SOL are committed to protecting the confidentiality of your nonpublic personal information. If you have questions about how your confidentiality is being protected, please do not hesitate to call us at (301) 881-3727.

Sincerely,

SOL Capital Management Company