Business Continuity Statement

McNicoll, Lewis & Vlak, LLC. (MLV) has established a firm wide business continuity plan to assess and manage the effects of a significant emergency disruption on its business operations in an effort to provide continuity of critical business functions. Such critical business functions include entering of client orders, completing securities transactions and providing clients' access to their accounts.

Consistent with regulatory requirements, MLV provides this disclosure statement to its clients summarizing the program. Due to the proprietary nature of some information, detailed plans for the program cannot be publicly disseminated.

As part of our plans, MLV has identified the applications that are critical to each of our business divisions. These applications are implemented in separate production and recovery data centers using industry-standard practices to copy data from the production site to the recovery site in real time. In most cases, recovery times will range from nearly instantaneous to approximately four hours. For some business functions, next-day recovery is projected.

The Plan is designed to account for the actions MLV will take in the event of disruptions of varying scope. This includes incidents involving the office building where MLV resides, city-wide or regional events of disruption. It also includes a plan for people loss, where staff members may be unable to work at their normal business location. The Plan has been reasonably designed to allow MLV to continue its business, likely at a reduced capacity, and safeguard the interests of our customers. MLV expects to be able to meet its client obligations within the day.

While MLV’s business continuity plan has been reasonably designed to allow the Firm to operate during emergency incidents of varying scope, such potential incidents are unpredictable. MLV has no control over certain infrastructure such as utilities, communication networks, transportation, and third party providers that BNP Paribas Securities may rely upon during an emergency. Because of the unpredictable and unknown nature of a potential future business disruption, MLV cannot guarantee that our systems will always be available or able to be recovered in the event of a serious emergency disruption. MLV’s business continuity plan is subject to change without notice. If the Plan is modified, an updated version will be posted on the Firm's website and will be made available to customers upon request. Nothing contained in this document amends or changes any of the terms set forth in any agreements between MLV and any of its customers.