BUSINESS CONTINUITY
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fixed income investment firm

BUSINESS CONTINUITY




Executive Business Continuity and Contingency Plan Disclosure

It is the policy of JVB Financial Group, LLC ("JVB") to maintain the services and support systems necessary to conduct uninterrupted business under regular and irregular conditions. This Business Continuity and Contingency Plan ("BCP") Disclosure is an overview of JVB's risk mitigation strategy in the event of a Significant Business Disruption ("SBD") of normal business activities. The BCP is designed to support all JVB obligations to customers in the event of an SBD. The BCP is intended to comply with obligations pursuant to regulatory rules and requirements as promulgated by the Financial Industry Regulatory Authority (FINRA).

It is the policy of JVB to respond to an SBD by safeguarding employees' lives and firm property, making financial and operational assessments, quickly recovering and resuming operations, protecting all of the firm's books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.

JVB maintains updated contact lists for all employees as well as specific lists as they relate to disaster recovery responsibilities. We can contact our employees through a number of methods, including communication via internal and external email and telephone as well as direct communication to specific employees. Our senior managers will be contacted directly in the event of an SBD.

JVB endeavors to ensure that all of its mission critical systems are backed up remotely and these backups can be activated in the case of an SBD. JVB performs maintenance of its backup systems throughout the year. In addition to backup systems on site, JVB maintains a full set of servers and support hardware that can easily be activated in a pre-designated remote location should business from our main office become unfeasible. JVB has reviewed and evaluated numerous scenarios in which emergency action may be required and developed a plan of action for each scenario. The content of these plans has been incorporated into our BCP.

Although JVB has made every effort to provide a working core in the event of a disaster, we acknowledge that the unpredictable nature of disasters precludes absolute preparedness. An unforeseen circumstance may arise that affects JVB in a negative way, however, our BCP is constantly undergoing improvement as we further identify these possibilities. In the event that our BCP is changed, a modified BCP will be posted to our website. You may obtain a hard copy of this BCP by calling (561) 939-1200.

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