In compliance with the privacy rule adopted by the Federal Trade Commission, this notice is given and made a part of our companies overall disclosure.

New federal legislation and regulations require us to provide this privacy statement and notice to describe how your personally identifiable information ("non public personal information"), which includes client and financial information, may be collected and shared, as well as the steps we take to protect this information from unauthorized access. This statement and the practices it describes, apply both to current and former clients effective July 1, 2001.

All client or prospect information acquired by or given to Mr. Benjamin R. Gooding and Gooding Capital Management will not be disclosed to anyone without the review and approval of Mr. Gooding.  No person except Mr. Gooding will have access to client information. Mr. Gooding will use the following guidelines for making his disclosure decisions.

Mr. Gooding has no intention of disclosing any client or applicant information except possibly for one or more of the following reasons:

1. To comply with written legal court orders, etc.

2. To comply with a verifiable government agency verbal and/or written request when warranted by governing regulations or audits (i.e., SEC).

3. To comply with a verifiable self regulating authority's verbal and/or written request when warranted by their governing regulations or audits (i.e., NASD, etc).

4. To applicable brokerage companies for the establishment and maintenance of an account.

5. To statement auditors (on a very limited basis) in the auditing of accounts for net performance purposes only. The auditors will not have access to any client information that is not printed on the client's monthly or annual statements.

6. To comply with a client's written request to do so.

Changes to our Privacy Notice: Our policy about obtaining and disclosing information may change from time to time. We will provide you with notice of any material change to this policy before we implement the change.

.