Newedge USA, LLC has developed a Business Continuity Plan that will be activated in the event of a significant business disruption. Because the timing and impact of disasters and disruptions are unpredictable, we design our plans to be flexible in responding to actual events as they occur.

Contacting Us - After a significant business disruption customers and others can contact us as usual at 646-557-9000 (New York), 312-762-1000 (Chicago), 713-266-0050 (Houston), 415-733-3000 (San Francisco), 816-360-6634 (Kansas City) and Philadelphia 215-981-1428 or visit our web site at www.newedgegroup.com where we will post a status of our anticipated recovery and provide alternative contact information as necessary. For US option or equity trade issues, call 800-949-2730 (Equities) or 800- 939-3504 (Options). For customers using www.fimatonline.com or www.fimacis.com or www.fimatpreferred.com, emergency information will also be posted on these web sites.

Plans: Detailed business continuity/disaster recovery planning documents have been prepared for all offices of Newedge USA, LLC.

Newedge USA, LLC plans 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; mission critical systems, functions, and employees; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical locations of employees; critical suppliers, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds.

Newedge operates its daily processing systems with a high level of redundancy using several information technology processing and backup sites. In addition we have arranged fully functional disaster recovery locations where key employees can operate if their regular office locations are unavailable. Employee communications are critical to a recovery plan. Newedge utilizes an automated notification system, an emergency hot-line, conference bridges, and call trees to enhance employee communications during a business disruption.

Varying Disruptions: Significant business disruptions can vary in their scope and severity, affecting just our firm, or a single building or a wider spread business district, city, or an entire region.

Our business continuity plan provides a multi pronged approach: 1) transfer of functions to other Newedge offices; 2) provision for some employees to work from home; and 3) activation of operations at a disaster recovery site. Alternatively, we may implement a combination of these arrangements.

Regular review: The disaster recovery plans are reviewed, updated and re-issued regularly.

All back-up facilities have sufficient space to accommodate key employees and are equipped with the hardware, software, systems and facilities to support the critical business functions. The primary back-up facilities in the Chicago and New York areas are also positioned on telecom and electrical grid systems that are different from the operating office.

Testing at disaster recovery sites: Back-up facilities undergo regular testing of computer systems and connections by both IT and critical personnel.

This disclosure is not intended as a substitute for the firm's full business contingency plans and does not claim to anticipate the firm's response to every potential disaster scenario.

In addition to its location on the company website (www.newedgegroup.com), hard copies of this disclosure may also be obtained upon request.

For more information - If you have any questions about our business continuity planning, you can contact Arnie Schafman, Business Continuity/Disaster Recovery Manager at 312-762-1000.

Disclaimer - The Firm's comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in the event of an emergency or significant business disruption; however it is not infallible. The BCP is designed to work in many different emergency situations; but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. Furthermore, although we are confident in our own preparedness, Newedge has no control over the various entities that we must rely upon in the event of an emergency. Our business continuity plans are tested periodically to ensure readiness; yet such tests may not be able to replicate the actual conditions we experience in a real emergency. This BCP is subject to change without notice. In the event that this BCP is modified, the updated document will be promptly posted on the Newedge website. Alternatively, customers may obtain an updated hard copy of the BCP upon request. The information contained in this disclosure is provided by Newedge for informational purposes only. Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any customer agreement between you and Newedge. Customers of firms that introduce accounts to Newedge must look to the business continuity plans of their introducing firm for guidance. Each NYSE or NASD member firm that introduces accounts to Newedge is required to develop and maintain its own business continuity plan independent of Newedge's BCP.