Business Continuity Plan

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses:

• data back-up and recovery; all mission critical systems; financial and operational assessments
• ensure that data loss levels are at a minimum
• alternative communications with customers, employees, and regulators
• assuring our customers prompt access to their funds and securities if we are unable to continue our business

Additional information on our BCP can be provided to interested managers and their advisors.