Pursuant to SEC Regulation S-P (Privacy of Consumer Financial Information) the Directors of the Boulder Growth & Income Fund, Inc., Boulder Total Return Fund, Inc., and First Opportunity Fund, Inc.™ and the Denali Fund, Inc., (the “Funds”) have established the following policy regarding information about the Funds’ shareholders. We consider all shareholder data to be private and confidential, and we hold ourselves to the highest standards in its safekeeping and use.

General statement

The Funds may collect nonpublic information (e.g., your name, address, email address, Social Security Number, Fund holdings (collectively, “Personal Information”)) about shareholders from transactions in Fund shares. The Funds will not release Personal Information about current or former shareholders (except as permitted by law) unless one of the following conditions is met: (i) we receive your prior written consent; (ii) we believe the recipient to be you or your authorized representative; (iii) to service or support the business functions of the Funds (as explained in more detail below), or (iv) we are required by law to release Personal Information to the recipient. The Funds have not and will not in the future give or sell Personal Information about their current or former shareholders to any company, individual, or group (except as permitted by law) and as otherwise provided in this policy.

In the future, the Funds may make certain electronic services available to their shareholders and may solicit your email address and contact you by email, telephone or US mail regarding the availability of such services. The Funds may also contact shareholders by email, telephone or US mail in connection with these services, such as to confirm enrollment in electronic shareholder communications or to update your Personal Information. In no event will the Funds transmit your Personal Information via email without your consent.

Use of Personal Information

The Funds will only use Personal Information (i) as necessary to service or maintain shareholder accounts in the ordinary course of business and (ii) to support business functions of the Funds and their affiliated businesses. This means that the Funds may share certain Personal Information, only as permitted by law, with affiliated businesses of the Funds, and that such information may be used for non-Fund-related solicitation. When Personal Information is shared with the Funds’ business affiliates, the Funds may do so without providing you the option of preventing these types of disclosures as permitted by law.

Safeguards regarding Personal Information

Internally, we also restrict access to Personal Information to those who have a specific need for the records. We maintain physical, electronic, and procedural safeguards that comply with Federal standards to guard Personal Information. Any doubts about the confidentiality of Personal Information, as required by law, are resolved in favor of confidentiality.