PPM America
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PPM AMERICA, INC.
Effective June 26, 2001

Summary
PPM America, Inc. (PPM) does not have individual customers as defined in the Gramm - Leach - Bliley Act (i.e.: An individual who obtains or has obtained a financial product or service used primarily for personal, family, or household purposes). PPM, however, is required to send out notices regarding our privacy policy on certain investment vehicles as stated under Regulation FD. Certain CBOs and other investment products sponsored by PPM (Funds) that have individual investors are included under the regulation. Because those Funds are unregistered, they are required by FTC regulations (not the SEC) to provide privacy notices to individual (not institutional) investors regarding their privacy policies. In general, PPM does not share nonpublic personal information regarding individual investors except as described in the statement below. Fund-specific notices for each of the Funds are sent annually to all their individual investors.

Privacy Policy
PPM collects certain nonpublic personal information about individuals who invest or consider investing in an affiliated Fund. In the context of those Funds, PPM retains personally identifiable financial information about investors, such as the amount of their interests in the Funds and representations about their assets, income, and their investment. Investors provide PPM with some of this information when they invest in the Funds and when they engage in certain Fund transactions. In addition, PPM receives information about investors from companies that provide services to the Funds.

This privacy policy applies only to investors who are individuals. PPM's privacy policy and practices apply equally to nonpublic personal information about former investors in the funds and individuals who inquire about investing in the Funds.

Information Collected and Disclosed
This privacy policy relates to nonpublic personal information that is personal to certain investors and possibly their family and generally includes information provided by investors to PPM in their Fund Subscription Agreement, such as: name, address and telephone and social security numbers; employment information, including salary; and information relating to investors' financial situation, including income and assets and liabilities and debts.
PPM may disclose all of the information we collect about Fund investors to affiliates, to persons that provide necessary services to the affiliated Fund, such as its trustee, custodian, administrator, and accountants, or as permitted by law or authorized by you. For example, PPM may disclose this information:
. To government entities, in response to subpoenas or to comply with laws or regulations
. When the investor directs us to do so or consents to the disclosure
. To companies that perform necessary services for the Funds, such as external auditors, outside counsel, and service providers that process or service transactions (such as the custodian, broker-dealers, and banks)
. To protect against fraud
. To collect unpaid debts
 
Internet Privacy Considerations
If an individual visits PPM's Web site, they will travel through the Web site pages anonymously. PPM tracks only the fact that someone has entered the site and has visited certain pages.

Investors who choose to view their account information online will find that their personal financial information is secured by state-of-the-industry technology, which as of this writing requires investors to have a username and password. All data transmission is encrypted with a sophisticated data encryption program and provides the highest level of security and privacy which PPM believes is currently available.

For security reasons, PPM uses cookies. A cookie is a small piece of information that gets entered into the memory of a visitor's Web browser. The cookie cannot be read by a Web site other than the one that placed the cookie. PPM does not require acceptance of cookies in order to visit the Web site.

Safeguarding Information
Access to nonpublic personal information about individual fund investors is limited to our employees, affiliates and, in some cases, third parties (such as the service providers described above) as permitted by law. PPM maintains physical, electronic, and procedural safeguards to guard nonpublic personal information about investors.

PPM reserves the right to change this policy, or any supporting or related policies or procedures at any time.