Business Continuity Plan

LPS Capital (LPSC) has developed a Business Continuity Plan outlining 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 at (212) 441-3800, you should call our alternative number 516 414 8711. If you cannot access us through either of those means, you should contact our clearing firm, ICBC Financial Services (“ICBC”) at (212) 993-7357 for instructions on how it may provide prompt access to funds and securities, execute orders and process other trade-related, cash, and security transfer transactions for your customer.

Our 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; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm has the ability for real time back up capability of our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments as they occur. Your orders and requests for funds and securities could be delayed during this period.

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 2 hours.

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 1 business day. 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.

If the Securities Investor Protection (SIPC) determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist the appointed trustee by providing our books and records identifying customer accounts subject to SIPC regulation.

Additional Contacts

Securities Investor Protection Corporation
805 15th Street, NW, Suite 800
Washington DC 20005-2215
202-371-8300
www.sipc.org

ICBC Financial Services
1633 Broadway, 28th Floor
New York, NY 10019
(212) 993-7357

For more information – Should you have any questions concerning our business continuity plan, you may submit a written request for additional information to our Compliance Department at compliance@lpscptl.com or you may contact us direct at (212) 441-3800.

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