FALCO Financial Services, Inc.

Policy

As a registered investment adviser, FALCO Financial Services, Inc. must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisers to adopt policies and procedures to protect the “nonpublic personal information” of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information. Nonpublic personal information includes nonpublic “personally identifiable financial information” plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by FALCO Financial Services, Inc. to clients, and data or analyses derived from such nonpublic personal information.

Procedure

FALCO Financial Services, Inc. has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which may be summarized as follows:

Non-Disclosure of Client Information

FALCO Financial Services, Inc., maintains safeguards to comply with federal and state standards to guard each client’s nonpublic personal information. FALCO Financial Services does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:

As necessary to provide the service that the client has requested or authorized, or to maintain and service the client’s account;
As required by regulatory authorities or law enforcement officials who have jurisdiction over FALCO Financial Services, or as otherwise required by any applicable law; and
To the extent reasonably necessary to prevent fraud and unauthorized transactions.

Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside FALCO Financial Services, including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the client.

Security of Client Information

FALCO Financial Services, Inc. restricts access to nonpublic personal information to those employees who need to know such information to provide services to our clients.

Any employee who is authorized to have access to nonpublic personal information is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving nonpublic personal information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Privacy Notices

FALCO Financial Services, Inc. will provide each natural person client with initial notice of the firm’s current policy when the client relationship is established. FALCO Financial Services, Inc. shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If, at any time, FALCO Financial Services, Inc. adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies. The Compliance Officer is responsible for ensuring that required notices are distributed to the FALCO Financial Services, Inc. consumers and customers.