We at MFP Partners, L.P. (the “Partnership”) are concerned about the privacy of our investors. Our General Partner, MFP Investors LLC, became an SEC-registered investment advisor on February 25, 2012. As a registered investment advisor, we are required to adopt policies and procedures to protect the “nonpublic personal information” of natural person investors and to disclose to such persons the policies for protecting that information. We are sending this notice, which summarizes the Partnership’s policies and practices with respect to the treatment of nonpublic personal information that we acquire about our investors. The provisions of this policy apply to current and former investors in the Partnership and are subject to change.

  1. We collect nonpublic personal information about investors from the following sources:

    • Information received in subscription documents and other forms and questionnaires submitted to the Partnership, such as name, address, social security or tax identification number; eligibility to invest in new issues; and employment, asset, income and other household information.
    • Information we receive and maintain relating to a Partner’s capital account, such as profit and loss allocations and capital withdrawals and additions.
    • Information we receive about a Partner from the Partner’s purchaser representative, financial advisor, investment consultant or other financial institution, attorney, accountant or other authorized representative of a Partner with whom the Partnership has a relationship and/or whom the Partner may have authorized to provide such information to the Partnership.

    This information may be received in any manner, including in-person discussions, telephone conversations and electronic or other written communications.

  2. We do not disclose any nonpublic personal information about the Partnership’s investors to anyone other than the Partnership's affiliates without permission, except as required or permitted by law. The exceptions include third parties that assist the Partnership in providing you with services, such as our counsel, accountants and auditors, and financial service providers such as the Partnership’s prime brokers and custodians who assist the Partnership as part of the ordinary course of servicing your investment in the Partnership. We also may disclose information about a Partner to persons acting in a fiduciary or representative capacity on behalf of a specific Partner, such as an IRA custodian or Trustee of a grantor trust.

  3. We restrict access to nonpublic personal information about you to those employees and agents who need to know that information in order to provide services to you. We maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard your nonpublic personal information.

  4. We will continue to adhere to our privacy policy with respect to information that we have acquired about you, even if we no longer provide services to you.

  5. We note, however, that, notwithstanding the foregoing, we reserve the right to disclose nonpublic personal information about investors to any person or entity, including, without limitation, any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over us or our affiliates, if (i) we determine in our discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non-U.S., law, rule, regulation, executive order or policy, including, without limitation, any anti-money laundering law and the PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy.

  6. We reserve the right to change these policies and practices at any time and will provide you with a notice describing the revised policies. In addition, the Partnership’s privacy policy will be sent to you annually.

If you have any questions about the Partnership’s privacy policies, please contact our General Counsel, Timothy E. Ladin, at (212) 752-7345 or tladin@mfpllc.com.