de Garmo & Kelleher
a division of BB&T Asset Management, Inc.
Client Privacy Statement

GUIDING PRINCIPLES
The trust which exists between de Garmo & Kelleher and its clients is the most important asset of our investment counsel firm. Both de Garmo & Kelleher and its parent, BB&T Asset Management, Inc. recognize that your confidence in us encompasses our commitment to the protection of your personal information to the best of our ability. Knowing that all our clients value their privacy, we have not and will not disclose any personal information to anyone or any party, except as required by law; or at your direction; or as is necessary to provide you with ongoing services, as in the execution of transactions on your behalf. The firm has not and will not sell any personal client information to any party and will not provide it to the affiliates of BB&T Asset Management, Inc. without your consent.

Despite these existing principles and practices at de Garmo & Kelleher, concern arose that similar standards were not uniformly in place within the financial industry. This in turn led to a new Securities and Exchange Commission regulation, requiring registered investment advisers (along with banks; brokers; etc.) to provide a statement such as this to existing clients and to new ones as a relationship is established. Any material change in the provisions outlined below will require a fresh disclosure be sent to all clients. In addition, all clients are to receive a copy of this statement annually. The following is a statement of our privacy procedures, in place for your protection:

THE PERSONAL INFORMATION THAT WE COLLECT, MAINTAIN, AND COMMUNICATE
de Garmo & Kelleher collects, maintains, and conveys personal information so we can provide investment management services to you. The types and categories of such information include:

• Information we receive from you to open an account or provide investment advice to you (such as your home address, telephone number, and financial information);
• Information that we generate to service your account (such as trade tickets and account statements);
• Information that we may receive from third parties with respect to your account (such as trade confirmations and monthly statements from brokerage firms or other custodians of your securities);
• Information of a tax or legal nature which we may receive directly from you or from such professionals acting on your direction.

In order for us to provide investment management services to you, access to your personal information in very limited instances might be available as follows:

• Disclosures to companies - subject to strict confidentiality agreements - that perform services on our behalf (such as technology consultants who assist us in maintaining our computer systems); and
• Disclosures to companies as permitted by law, including those necessary to service your account (such as providing account information to brokers and custodians as well as tax data to accountants).

HOW WE PROTECT YOUR PERSONAL INFORMATION
To fulfill our privacy commitment at de Garmo & Kelleher and its parent, BB&T Asset Management, Inc. we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:

• Adopting policies and procedures that put in place physical, electronic, and other safeguards to keep your personal information safe.
• Limiting access to personal information to those employees who need it to perform their job duties.
• Requiring third parties that perform services for us to agree by contract to keep your information strictly confidential.
• Protecting information of our former clients to the same extent as our current clients.