Regulation S-P, adopted by the Securities and Exchange Commission, is designed to protect the privacy of individuals who obtain financial products or services. The following describes how The Elite Group, McCormick Capital Management Inc., and PFPC Inc. handle your nonpublic personal information, and what steps we take to protect your privacy.

Who We Are
The Elite Group, including the Elite Growth & Income and Elite Income Funds (the "Funds"), is a regulated investment company registered under the Investment Company Act of 1940 and Securities Act of 1933. McCormick Capital Management, Inc. is a registered investment advisor under contract to manage the assets of the Funds. The Board of Trustees of The Elite Group has also contracted with PFPC Inc. to provide services to shareholders of the Funds, including establishing and maintaining shareholder accounts. PFPC maintains the original account application and other documentation necessary to provide these and other services.

Accessing Information
Access to shareholder nonpublic personal information is authorized for business purposes only. It is based on our need to know such information to better assist you in making informed investment decisions. The Elite Group, McCormick Capital Management, and PFPC require its employees to protect and keep shareholder nonpublic personal information confidential.

Collection Information to Conduct Business
Information collected is used to provide for your financial needs, for customer service, to offer new products or services and to fulfill legal and regulatory requirements. The type of information collected may include (but is not limited to): name, address, social security number, date of birth, assets, income, beneficiaries for retirement accounts, and banking relationships. Other information collected over the life of the account may include a history of account deposits, withdrawals, holdings and account balances.

Security Standard
The Elite Group, McCormick Capital Management and PFPC Inc. continue to assess new technology and processes to provide additional protection of your personal information. We safeguard this information in accordance with federal standards and established security standards and procedures. Measures we take in this regard include implementation of physical, electronic, and procedural safeguards.

Sharing Information
In the normal course of conducting business, we may disclose some or all of the previously described information about you to other businesses including non-affiliated third parties, but only as allowed by law, and:

In response to a subpoena, to prevent fraud, or to comply with an inquiry by a government agency or regulators.

Providing customer service or account maintenance including the development or maintenance of computer software.