PRIVACY POLICY

HCI is committed to protecting the confidentiality and security of information we collect about our customers. We will not share nonpublic information about you ("Information") with third parties outside of our clearing firm(s) without your consent, except for the specific purposes described below. This notice describes the Information we may gather and the circumstances under which we may share it.

Why We Collect and How We Use Information:

We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes processing transactions requested by you and administering our business.

How We Gather Information:

We get most Information directly from you, when you apply for, access and use financial products and services offered by Halpern Capital and its business partners - whether in person, by telephone or electronically. We may verify this information or get additional information from consumer reporting agencies or public sources. This Information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with us, our affiliates, or others.

How We Protect Information:

Our employees are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer our products or services. We also maintain physical, electronic and procedural safeguards to protect Information which comply with all applicable laws. Employees who violate our Privacy Policy are subject to disciplinary process.

Disclosure of Information:

We do not disclose any nonpublic information about our customers or former customers to anyone, except as permitted by law. We may disclose any Information to or as directed by our clearing firm(s) or when we believe it necessary for the conduct of our business, or where disclosure is required or permitted by law. Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies, for example, to help us prevent fraud. In addition, we may disclose Information to affiliated and non-affiliated third party service providers (i) to enable them to provide business services for us or our clearing firm, such as performing computer related or data maintenance or processing services, (ii) to facilitate the processing of transactions requested by you, (iii), to assist us in offering products and services to you or to assist our clearing firm in offering products and services to you, or (iv) for credit review and reporting purposes. Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company. It is Halpern Capital's policy to require all third parties, other than our clearing firm(s) and affiliates, that are to receive any Information to sign strict confidentiality agreements.

Former Customers:

Even if you are no longer a customer, our Privacy Policy will continue to apply to you.

To Whom This Policy Applies:

This Privacy Policy applies to products or services provided by Halpern Capital to its customers. Access to and Correction of Information: If you desire to review any file we may maintain for your personal Information, please contact us. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.

Access to and Correction of Information:

If you desire to review any file we may maintain for your personal Information, please contact us. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.

Further Information:

We reserve the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with a recently enacted federal law and new SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.

ANTI-MONEY LAUNDERING REQUIREMENTS

The USA PATRIOT Act

The USA PATRIOT Act is designed to detect, deter, and punish terrorists in the United States and abroad. The Act imposes anti-money laundering requirements on brokerage firms and financial institutions.

What is money laundering?

To help you understand these efforts, we want to provide you with some information about money laundering and our steps to implement the USA PATRIOT Act. Money laundering is the process of disguising illegally obtained money so that the funds appear to come from legitimate sources or activities. Money laundering occurs in connection with a wide variety of crimes, including illegal arms sales, drug trafficking, robbery, fraud, racketeering, and terrorism.

How big is the problem and why is it important?

The use of the U.S. financial system by criminals to facilitate terrorism or other crimes could well taint our financial markets. According to the U.S. State Department, one recent estimate puts the amount of worldwide money laundering activity at $1 trillion a year.

What are we required to do to eliminate money laundering?

Under the USA PATRIOT Act, our anti-money laundering program must designate a special compliance officer, set up employee training, conduct independent audits, and establish policies and procedures to detect and report suspicious transactions and ensure compliance with the new laws. As part of our required program, we may ask you to provide various identification documents or other information. Until you provide the information or documents we need, we may not be able to open an account or effect any transactions for you.

We thank you for your patience and hope that you will support us in our efforts to deny terrorist groups access to America's financial system.

FIRM COMPENSATION

HCI seeks to earn revenue from customer transactions and Investment Banking activites. HCI follows regulatory requirements concerning any fees charged to you and in reporting transaction fees to you.

PAYMENT FOR ORDER FLOW

The Securities and Exchange Commission ("SEC") requires each brokerage firm to disclose its policy regarding the receipt of "payment for order flow." We wish to inform you that, at this time, HCI does not have any written payment for order flow agreements but may enter into such agreements at any time. HCI currently receives rebates for adding liquidity to certain avenues of execution (e.g., ECNs).

DISCLOSURE OF ORDER ROUTING INFORMATION

Pursuant to SEC Rule 11Ac1-6, we will, upon your request, disclose to you the identity of the venue to which your directed and non-directed orders were routed for execution during the six months prior to your request, as well as the time of the transactions, if any, that resulted.

BEST EXECUTION

HCI seeks to execute its customer's orders at the most favorable terms reasonably available.

RISKS OF ACTIVE TRADING

You should carefully consider the following points before engaging in an active trading strategy or what is sometimes called "day trading." Active trading or day trading may be described as engaging in frequent purchase and sale transactions (at least several per week and, for some active traders, often numerous transactions per day) using systematic or strategic approaches.

• Active trading has a very high level of risk. Active trading generally is not appropriate for someone of limited resources or limited investment or trading experience or low-risk tolerance. You should be prepared to lose all of your funds that you invest in your trades. In particular, you should not fund this type of trading with retirement savings, student loans, second mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required to meet your living expenses.
• Be cautious of claims of large profits from active trading. You should be wary of advertisements or other statements that emphasize the potential for large profits from active trading. Active trading may result in few or no profits, and worse, may lead to large financial losses very quickly.
• Active trading requires sophisticated knowledge of securities markets. Active trading requires in-depth knowledge of the securities markets and of sophisticated and disciplined trading techniques and strategies. Also, you must compete with professional, licensed traders employed by securities firms and other knowledgeable, experienced and well-trained traders. You should have appropriate knowledge and experience before engaging in active trading.
• Active trading requires in-depth knowledge of your broker's operations. An important part of executing active trading strategies is the quality and consistency of the order execution services you use. Whether you use the services of professional brokers or electronic systems, your success will be affected by their strengths and weaknesses and the methods and practices of the brokerage firm in executing trades. You should develop an intimate knowledge of these matters before you engage in active trading.
• Active trading may result in you paying large commissions. You pay commissions on each trade you make. The more actively you trade, the more commissions will increase your losses or reduce your profits.
• Active trading on margin or short selling may result in losses beyond your initial investment account amount. When you actively trade with borrowed funds, you can lose more than you originally placed at risk. A decline in the value of the securities that are purchased may require you to provide additional funds to avoid the forced sale of those securities or other securities or collateral in or for your account. Short selling as part of your trading strategy also may lead to large losses, because you may have to purchase a stock at a very high price in order to cover a short position.

In summary, active trading is not a game. It is not recommended for inexperienced traders or for persons who do not have sufficient resources and time to devote to their trading activities. Active trading is a serious commitment that should not be undertaken unless you are able to handle high risk and high stress well, and are willing to consistently adhere to objective and disciplined trading strategies and approaches.

EXTENDED HOURS TRADING DISCLOSURE

• Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities and, as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, if at all.
• Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not executed at all, or you may receive an inferior price in extended hours trading than you would during regular market hours.
• Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening the next morning. As a result, you may receive a price in extended hours trading that is inferior to the one you would receive during regular market hours.
• Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive a price in one extended hours trading system that is inferior to the one you would in another extended hours trading system.
• Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity or higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
• Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

MARGIN DISCLOSURE STATEMENT

Your brokerage firm is furnishing this document to you to provide some basic facts about purchasing securities on margin, and to alert you to the risks involved with trading securities in a margin account. Before trading stocks in a margin account, you should carefully review the margin agreement provided by your firm. Consult your firm regarding any questions or concerns you may have with your margin accounts.

When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firm's collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities in any of your accounts held with the member, in order to maintain the required equity in the account.

It is important that you fully understand the risks involved in trading securities on margin. These risks include the following:

• You can lose more funds than you deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities in your account(s).
• The firm can force the sale of securities in your account(s). If the equity in your account falls below the maintenance margin requirements under the law, or the firm's higher "house" requirements, the firm can sell the securities in any of your accounts held at the firm to cover the margin deficiency. You also will be responsible for any short fall in the account after such a sale.
• The firm can sell your securities without contacting you. Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.
• You are not entitled to choose which securities in your account(s) are liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests.
• The firm can increase its "house" maintenance margin requirements at any time and is not required to provide you advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. Your failure to satisfy the call may cause the member to liquidate or sell securities in your account(s).
• You are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension.

BUSINESS CONTINUITY PLAN DISCLOSURE

Halpern Capital, Inc.(the “Company”) has established a company-wide business continuity planning program to assess and manage the effects of a significant emergency disruption on its business operations in an effort to provide continuity of critical business functions. Such critical business functions include communicating with customers regarding their transactions.

Consistent with regulatory requirements, the Company provides this disclosure statement to its clients summarizing the program. Due to the proprietary nature of some information, detailed plans for the program cannot be publicly disseminated.

The business continuity planning program begins with each business units' assessment of its business continuity risk. This process encompasses all aspects of the Company’s key business functions. The assessment defines, for each business process, its criticality and a method for recovery. Individual business unit plans are reviewed and updated annually, or as significant business changes occur.

The Plan is designed to account for the actions the Company will take in the event of disruptions of varying scope. This includes incidents involving a single office building where any of the Company’s offices may reside, city-wide or regional events of disruption. It also includes a plan for people loss, where staff members may be unable to work at their normal business location. The Plan has been reasonably designed to allow the Company to continue its business, likely at a reduced capacity, and safeguard the interests of our customers. The Company expects to be able to meet its client obligations within the business day.

While the Company’s business continuity plan has been reasonably designed to allow the Company to operate during emergency incidents of varying scope, such potential incidents are unpredictable. The Company has no control over certain infrastructure such as utilities, communication networks, transportation, and third party providers that the Company may rely upon during an emergency. Because of the unpredictable and unknown nature of a potential future business disruption, the Company can not guarantee that our systems will always be available or able to be recovered in the event of a serious emergency disruption.

Please note that the Company’s business continuity plan is subject to change and modification. You may obtain updated summaries of the plan by contacting us at the following telephone number or address:

 Halpern Capital, Inc. ,

 20900 NE 30^th Ave., Suite 200

 Aventura, FL  33180

 786-528-1400

INVESTOR EDUCATION AND PROTECTION

HCI is a member of the Securities Investor Protection Corporation ("SIPC"). SIPC plays an important role in the overall system of investor protection in the United States by, in certain specified situations, restoring funds to investors with assets in the hands of bankrupt and otherwise financially troubled brokerage firms. When a brokerage firm is closed due to bankruptcy or other financial difficulties and customer assets are missing, SIPC steps in as quickly as possibly and, within certain limits, works to return customers' cash, stocks, and other securities. You may obtain more information about SIPC, including a brochure entitled How SIPC Protects You, by contacting SIPC at:

Securities Investor Protection Corporation

805 15th Street, N.W. Suite 800 Washington, D.C. 20005-2215

Tel: (202) 371-8300 Fax: (202) 371-6728 Email: asksipc@sipc.org Web Site: www.sipc.org

HCI is required by FINRA Rules to provide you with information about the availability of information through the FINRA's Public Disclosure Program. Please be advised that FINRAoffers an investor brochure describing the Public Disclosure Program. The investor brochure may be obtained via the FINRA Wes Site (www.finra.org) or through NASD Public Disclosure Program Hotline Number at (800) 289-9999.

QUESTIONS ABOUT YOUR ACCOUNT

Pursuant to SEC Rule 17(a)-3(a)(18)(ii), complaints should be directed to Halpern Capital, Inc. ATT: Compliance, 20900 NE 30th Avenue Suite 200 Aventura, FL 33180 (786) 528-1402

Very truly yours, HALPERN CAPITAL, INC

January 2009