PRIVACY DISCLOSURE STATEMENT

COWEN & ASSOCIATES 4025 Caminito Davila San Diego, CA 92122   6/21/2001

Cowen & Associates' primary client goal is to protect your privacy.  To conduct regular business, we may collect nonpublic personal information from sources such as: Information reported by you on applications or other forms you provide to us Information about your transactions with us, our affiliates, or others As Cowen & Associates shares nonpublic information solely to service our client accounts, we do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.

FAIR CREDIT REPORTING ACT

[Disclosure under the above heading is only required if your firm must make disclosures under the Fair Credit Reporting Act.]

INFORMATION SAFEGUARDING

Cowen & Associates will internally safeguard your nonpublic personal information by restricting access to only those employees who provide products or services to you or those who need access to your information to service your account.  In addition, we will maintain physical, electronic and procedural safeguards that meet federal and/or state standards to guard your nonpublic personal information.

COLLECTION OF "INTERNET COOKIES"

Cowen & Associates does not collect "internet cookies" or attempt to count the number of "hits" to our web site: Cowenassociates.com.

SAFEGUARDS TO PROTECT YOUR NONPUBLIC PERSONAL INFORMATION

Cowen & Associates maintains physical files in our office space with your nonpublic personal information.  All documents containing your name or account number or any personal information are processed through a shredder before it is disposed of in the trash.  Only employees in the performance of their job are allowed to access these files.  Cowen & Associates sends to the web site daily or bi-monthly a summary of your portfolio in a "Centerpiece" format that is similar to the quarter end portfolio statements mailed each quarter.  This web site data has an expiration date of usually a week after delivery to the site.  These reports contain name, account number and investment detail only.  The web site is secure and clients must enter a password and id number to access their reports.  The web site is backed up each day for audit purposes and recovery procedures in the event of a crash of the site.