Business Continuity Plan

The following information concerns Cary Street Partners’ and First Clearing, LLC’s efforts to ensure that impact to your business is minimized in the event of an emergency or disaster.

Industry regulations require each broker-dealer and investment advisor to create and maintain a business continuity plan tailored to the size and need of the member and reasonably designed to enable the member to meet its existing obligations to its clients or other counter-parties. In accordance with these requirements, Cary Street Partners has designed a business continuity plan to address possible scenarios in efforts to minimize any service impact to our clients.

In keeping with the regulatory requirements, the business continuity plan for Cary Street Partners is designed to address key areas of concern — including, but not limited to, the following:

• Data back-up and recovery
• Mission-critical systems
• Financial and operational assessments
• Alternate means of communication between the firm and its clients
• Alternate means of communication between the firm and its employees
• Alternate physical locations of employees;
• Critical business constituent, bank and counter-party impact
• Regulatory reporting
• Communications with regulators
• How Cary Street Partners will ensure that clients have access to their funds and securities in the unlikely event that Cary Street Partners determines it is unable to continue its business

Since events creating disruption of business may vary in nature and scope, Cary Street Partners has anticipated scenarios in which the following are affected:

• A Cary Street Partners branch location
• A primary Cary Street Partners building at its headquarters location
• A citywide area
• A regional area

Regardless of the scope of potential disruption, Cary Street Partners will strive to continue to provide services to its clients.

In the event where a Cary Street Partners branch location is affected, the firm has designed a contingency plan where client telephone calls will automatically be re-routed to a separate location. Additionally, Cary Street Partners clients can access their accounts in various ways, including, but not limited to, telephoning Cary Street Partners direct, visiting any of our branch offices, or through our online services at ww.carystreetpartners.com. These alternative access methods are provided so that our clients are able to maintain consistent and constant access to their accounts.

In the unlikely event of a citywide or regional disruption, Cary Street Partners has established a recovery site approximately 70 miles from its headquarters that can be used to restore time sensitive functions as soon as key employees are relocated to the facility. In the event that any such disruption occurs, we have developed alternative service arrangements, systems, locations, and contingency plans to ensure that any service affected is quickly restored.

At a minimum, the Cary Street Partners business continuity plan is reviewed, updated, and tested on an annual basis. Additionally, our primary internal and external application providers periodically conduct testing of their own back-up capabilities to ensure that, in the event of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need to continue or promptly resume our business.

Making sure that any type of disruption does not unduly impact our clients is extremely important to us, and our business continuity plan is designed to allow us to continue to provide the quality service you have come to expect from Cary Street Partners.