BUSINESS CONTINUITY

An integral component of that service is providing you continued access to your account assets. In today’s world of electronic communications and networked businesses, various events could interrupt primary routines of conducting business. We would like to take this opportunity to assure you that we have plans in place for continuing service to our clients during business emergencies. Capulent, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us. If after a significant business disruption you cannot contact us as you usually do, you should call our alternative number (626) 319-4254. If you cannot access us through either of those means, you should contact the custodian for your respective investment.

Our Business Continuity Plan. 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. 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, allowing our customers to transact business. The plan addresses data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counterparty impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business. In the event a disruption prohibits the use of our main office, we have alternative locations available so we may continue to serve your financial needs.

Varying Disruptions. Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within a half-hour. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 4 hours. In either situation, we plan to notify you via email and through our website (www.capulent.com) of how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities. As with any matters of this importance, we are continually reviewing and evaluating our business contingency plans to implement improvements, and as such, the plan and this notice are subject to modifications. This notice in its most current form will be posted on our website.