Policies and Disclosures

Policy on Privacy of Consumer/Customer Non-public Information
The Gramm-Leach-Bliley Act of 1999 requires certain financial institutions to establish appropriate standards and policies to safeguard client records and information and to advise their clients of these standards and policies. These safeguards are intended to insure the security and confidentiality of client information and to protect against any unauthorized access or use. At Burke, Lawton, Brewer & Burke, LLC, and BLB&B Advisors, LLC, we highly value our client relationships and we do not disclose any nonpublic personal information about our clients to anyone, except as permitted by law. Set forth below is a notice, as required by the Gramm-Leach-Bliley Act, summarizing our privacy policy. If you would like more information regarding our privacy policy, please contact your portfolio manager.

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. Therefore, when you open an account, we will ask for information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents. In addition, as investment advisor and broker/dealer, we collect nonpublic personal information about you from the following sources: (1) Information we receive from you upon becoming a client or that is disclosed during the course of our relationship. (2) Information about your transactions with us, our affiliates, and others.

We do not disclose any nonpublic personal information about you or our former clients, except as permitted by law or as authorized by you. To assist us in offering you services, we share information with companies that act for us on your behalf, such as data processing companies or brokerage clearing firms. These companies assist us in providing a particular service and are obligated to keep the information that we provide to them confidential.

As investment advisor and broker/dealer, we restrict access to your personal and account information to those employees who need to know that information in order to provide services to you. We maintain physical, electronic, and procedural safeguards that protect your nonpublic personal information.

Proxy Voting Policy
BLB&B Advisors, LLC (BLADV) encourages its clients to receive all mailings from the companies in which they are invested. Corporate mailings typically include quarterly and annual reports as well as all annual meeting and proxy voting material. Clients should vote their proxies as they see fit. On occasion there may be instances when BLADV votes on behalf of clients. If this occurs, it is BLADV's proxy voting policy to vote in the best financial interests of its clients. More often that not, this translates to voting as company management recommends. In cases where the financial interests of our clients differ from management's recommendations we would not side with management.

Our underlying philosophy is that when we invest in a particular company, we strive to support the way current management runs the company, otherwise we would not be investing in the company. Our goal is not necessarily to change company policy through our vote based upon a prevailing social fad or issue. To the extent we lose confidence in management's ability to operate the company, we would be inclined to sell the underlying security rather than attempt to "back seat" manage the company through our voting on a particular matter. In a remote instance such as described, we would tend to vote against management and sell the shares at the appropriate time, which we would consider in the best financial interest of the client.

If BLADV votes a proxy on your behalf, you have the right to request and receive information from BLADV concerning how your vote was cast. You may do so by writing to BLADV and requesting such information.

Business Continuity Disclosure Policy
Burke, Lawton, Brewer & Burke, LLC (BLB&B) is a full-disclosed broker dealer, clearing through First Clearing, LLC (FC), a subsidiary of Wachovia Bank, N.A. In accordance with security industry regulations, BLB&B has devised a business continuity plan to address possible scenarios in an effort to minimize any service disruption to our clients.

In keeping with the regulatory requirements, our business continuity plan is designed to address key areas of concern, including but not limited to the following:

• Data back-up and recovery
• All mission critical systems
• Financial and operational assessments
• Alternate means of communication with our customers
• Alternate means of communication with our employees
• Alternate physical locations of employees
• Critical business constituent, bank and counter-party impact
• Regulatory reporting
• Communications with regulators
• Since events creating business disruptions may vary in nature and scope, BLB&B has anticipated scenarios in which the following are affected
• our office
• the regional area

Regardless of the scope of potential disruption, BLB&B intends to continue to provide service to its clients.

In the event where our building is affected, the firm has a secondary location eight miles away where operations can be easily reestablished.

In the unlikely event of a regional disruption, BLB&B has the ability to establish basic operations through the use of laptop computers maintained in more distant locations. As a result of our clearing arrangement with FC, the firm can access client records through a secure internet site, which can be accessed anywhere our laptop computers are taken. Trading and access to client funds is available from multiple locations at anytime through the use of telephones and cellular telephones.

In the event that any such disruption occurs, we have developed alternative service arrangements, systems, locations and contingency plans to ensure that any service is quickly restored.

At a minimum, our business continuity plan is reviewed on an annual basis. Additionally, our primary internal and external application providers periodically conduct testing of their own back-up capabilities to ensure that, in the event of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need to continue or promptly resume our business.

Making sure that any type of disruption does not unduly impact our clients is extremely important to us, and our business continuity plan is designed to allow us to continue to provide the quality service you have come to expect from BLB&B.

Custody of Assets Rule 206(4)-2
BLB&B Advisors, LLC would like to remind its clients that, in conformity with SEC Rule 206(4)-2, BLB&B Advisors, LLC, as an investment advisor, is not permitted to take delivery of or maintain custody of client assets.

Requesting Part II Form ADV
In accordance with current regulations governing investment advisors, please note that BLB&B Advisors, LLC has copies of Part II of its Form ADV available for client review. Part II of the Form ADV provides information about an investment advisor and its business. If you would like a copy of Part II, please direct your request in writing to Laura W. Brewer, or stop by our office.

Routing of Equity Trades 11ac1-6 Report
In accordance with SEC regulations, please note that First Clearing Corp., as clearing agent for Burke, Lawton, Brewer & Burke, LLC, has prepared a report detailing the routing of customer orders. All orders placed by Burke, Lawton, Brewer & Burke, LLC are done through FCC who in turn places the order with an execution venue of its choosing. Please click here to view the SEC-Required Report on Routing of Customer Orders for the current quarter

First Clearing LLC Statement of Financial Condition
To see the most recent copy of the First Clearing Statement of Financial Condition, click here.