Pursuant to Title V of the Gramm-Leach-Bliley Act (GLBA) and the U.S. Securities and Exchange Commission’s (SEC) Regulation S-P (17 CFR 248.1-248.30), we are required to notify you of Vanderbilt Securities, LLC’s (VS) Privacy Policy. This disclosure is intended to notify you of the uses we make of the non-public financial and personal information we obtain about you in the course of providing brokerage services for you.VS is a New York Limited Liability Company with a main office located in Melville, New York. We are an introducing securities broker-dealer, with our transactions clearing through another registered broker-dealer, Bear, Stearns Securities Corp. (BSSC). You should have received a separate disclosure regarding BSSC’s Private Policy. VS is registered with the SEC and a member of the National Association of Securities Dealers, Inc. (NASD), and the Securities Investor Protection Corporation (SIPC).In order to transact securities business on your behalf, we obtain a variety of non-public financial and personal information about you.

In addition, we maintain a record of your securities transactions, which is also non-public. We obtain and maintain records of this information only for the purpose of maintaining the business of being a securities broker-dealer, and in compliance with applicable federal, state and self-regulatory organization rules.

NO SALE OF YOUR NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION

VS DOES NOT SELL YOUR NON-PUBLIC FINANCIAL OR PERSONAL INFORMATION

NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION COLLECTED

The information collected and maintained by VS in transacting securities information on your behalf includes, or may include, the following types of non-public financial and personal information:1. Information from you: information you provide on new account form(s); whether provided in writing, in person, by telephone or facsimile, via electronic communication or any other means; such as your name, telephone number, address, social security number, tax ID number, assets, income, investment objectives, financial situation, employer, age and previous securities experience.2. Information about your securities and/or other transactions: (a) information VS collects and relates to account(s) balance, payment history, trading activity and any other transactions, which take place through or affect transactions which take place through VS; and (b) information VS collects as part of servicing your account(s).

3. Information about your transactions with non-affiliated third parties: (a) information from non- affiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and (b) information from non-affiliated third parties related to servicing your account(s).

NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND NON-AFFILIATED

THIRD PARTIES

VS discloses to affiliated and non-affiliated third parties non-public financial and personal information only in connection with the conduct of its securities brokerage business. Such disclosures may include, among other things, information related to transactions, settlement, billing, payment, processing, clearing, transferring, reconciling, collection or tax reporting. Disclosures may be made to affiliates or non-affiliated third parties: (1) as required or necessary to carry out fully and properly the securities business conducted by VS (e.g. to service providers supplying document processing and delivery, data maintenance or processing services, to BSC for clearing purposes and to non-affiliated clearing agencies or entities); (2) as required by law or legal process; (3) with your consent; (4) to resolve customer disputes; (5) when requested by a fiduciary or beneficiary on the account; (6) when requested by the client’s attorney(s) or accountant(s); (7) when required by a regulatory agency, or for other reasons required or permitted by law; or (8) in connection with a sale or merger of the firm’s business.

FORMER CUSTOMERS

The same protections for non-public financial and personal information of current customers of VS apply to information regarding former customers: disclosure is made only as permitted/required by law or legal process, or with your consent.

CONFIDENTIALITY AND SECURITY OF NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION

VS is committed to implementing and maintaining commercially reasonable and appropriate measures to maintain the privacy and confidentiality of the non-public financial and personal information we collect and maintain about you. Our procedures for insuring this include, at a minimum, the following:

•Access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals, as well as physical access controls.