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      Lamont Trading Advisors, 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 include the following:

Non-Disclosure of Client Information
     Lamont Trading Advisors, Inc. maintains safeguards to comply with federal and state standards to guard each client's nonpublic personal information. Lamont Trading Advisors, Inc. 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 Lamont Trading Advisors, Inc., 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 Lamont Trading Advisors, Inc., 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 and Disposal of Client Information
     Lamont Trading Advisors, 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. Any employee who is authorized to possess "consumer report information" for a business purpose is required to take reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal.

Privacy Notices
      Lamont Trading Advisors, Inc. will provide each natural person client with initial notice of the firm's current policy when the client relationship is established. Lamont Trading Advisors, 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, Lamont Trading Advisors, 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 Lamont Trading Advisors, Inc.'s consumers and customers.