Privacy Statement
      On November 12, 1999, the President signed into law the Gramm-Leach-Biley Act (GLB). Title V of the GLB set forth privacy requirements for use of nonpublic personal financial information by banks, securities industry members, insurance companies, and other financial institutions. As a result, the Securities Exchange Commission (SEC) has issued Regulation S-P with which to govern the collection, use and safeguarding of nonpublic personal financial information by its members. Since the SEC governs the National Association of Securities Dealers of which CWS is a member, we must comply with this new regulation, which goes into effect on July 1, 2001.

      CWS does not disclose and does not wish to reserve the right to disclose nonpublic personal information regarding its investors to its affiliates and non-affiliated third parties, unless permitted by law. This policy is strongly enforced at CWS.

Categories of Information Collected
      We collect nonpublic personal information about you from the following sources:

1. Information we receive from you on Subscription Agreements and New Account forms; and
2. Information about your transactions with us.

Confidentiality and Security
      We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products and services to you. CWS maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information.

Summary
      In closing, we believe that Regulation S-P is of utmost importance to secure the privacy of consumers. You will receive an annual notice regarding our compliance to Regulation S-P, such as this one, each year, as well as a revised notice in the event any of our above stated policies change.