In compliance with SEC Regulation SP clients are notified annually of our policies and procedures regarding how their records are maintained. Gagnon Securities has a long-standing policy committed to protecting our clients’ confidentiality and the security of all information obtained from our clients. Prior to opening an account with us, we obtain directly from our clients their personal and financial information. This information is used by your broker and our management team to evaluate suitability for our investment approach as well as to determine how together we can meet your individual investment goals. Periodically we will ask clients to furnish us with updated information.

All Gagnon Securities personnel have access to this information for administrative purposes. All clients’ files and records are kept within a secured area of our office clearly marked “Authorized Personnel Only.” Our employees are required to protect our clients’ confidentiality and access information only when appropriate to do so. Violators of our policies would be subject to disciplinary and/or legal action per our confidentiality agreement that all employees are required to sign.

All of our accounts clear through Bear, Stearns Securities Corporation on a fully disclosed basis; all information and documentation pertaining to client accounts are forwarded to them at the time an account is opened. Bear Stearns maintains this information and records all account activity. Bear Stearns has its own privacy policy that it forwards to clients under separate cover.

It is Gagnon Securities’ policy not to share or disclose any information to any persons or business entity except as permitted by law or when specifically directed to do so by our clients in writing. If you have any questions or concerns regarding these procedures, please call our Compliance Office at 212.554.5050.