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Sam Badgley Inc. as a Registered Investment Advisory Firm, is covered under the definition of a “financial institution” under the Federal Gramm-Leach-Bliley Act. To maintain compliance, every broker, dealer, investment company, and registered investment adviser is required to adopt policies and procedures reasonably designed to safeguard customer records and information. Sam Badgley Inc. maintains compliance under the Act and with the Securities and Exchange Commission’s Regulation S-P (“Privacy Rule”).

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