PRIVACY POLICY

January 2008

We at Howard Weil Incorporated consider the protection of your sensitive personal information to be an important priority.  We designed our privacy policy and practices to support this objective.  We want our customers to understand what information we collect and how we use it.

From time to time, we may collect a variety of personal information about you, including:

v  Information we receive from you on applications and forms, via the telephone, and through our website;

v  Information about your transactions with us, our affiliates, or others, including specific securities purchases, sales and gains or losses, account balances and commissions charged; and

v  Information we receive from consumer reporting agencies.

We do not disclose your nonpublic personal information, except as permitted by applicable law or required by regulatory authorities. For example, we may share this information with others in order to process your transaction. We may also provide this information to companies that perform services on our behalf, such as printing and mailing. We will require these companies to protect the confidentiality of this information and to use it only to perform the services for which we hired them.

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you.

With respect to our internal security procedures, we maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information, and we restrict access to this information.

If your relationship with us should terminate or become inactive, we will continue to adhere to our privacy polices and practices with respect to your nonpublic personal information.

Howard Weil Incorporated