BUSINESS CONTINUITY PLAN DISCLOSURE

Banc of Manhattan Capital (“BOM” or the “Firm”) is committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. This Business Continuity Plan Disclosure (the “BCP”) summarizes BOM’s effort to mitigate risks inherent with unforeseen business interruptions. 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. This BCP is intended to comply with the rules promulgated by the New York Stock Exchange (“NYSE”) and Financial Industry Regulatory Authority (“FINRA”).

OVERVIEW

BOM maintains 1 primary and 1 alternate facility to house the backbone of our operations and information technology. These two facilities are located far enough apart to diminish risks posed by local disruptions. This separation is a key element of the Firm’s overall business continuity strategy. This separation allows us to plan for events at each location individually, since no one event should effect more than a single location simultaneously. The benefit of having only one site in each location means our response to an event will be the same whether the event is a firm-only business disruption, a disruption to a single building, a disruption to a business district or a city-wide business disruption.

COMMUNICATION WITH OUR EMPLOYEES IN THE EVENT OF A DISRUPTION

The safety and well-being of our employees is a vital concern. In the event of an emergency or significant business disruption, the Firm will communicate with its employees in several different ways. We use a combination of telephone, facsimile, e-mail, and mobile phone. General information such as office closures and operating hours will sent via e-mail to registered and non-registered employees on the Firm’s contact lists.

MISSION CRITICAL SYSTEMS

Our Firm conducts business exclusively in (1) Broker selling corporate debt securities (2) U.S. government securities broker (3) Engage in transactions of asset backed mortgage backed securities on an agency basis (4) Consulting assignments on fee basis to companies buying and selling closed mortgage loans (5) Trading securities for own account. Therefore, our only mission critical systems are our internal electronic and paper records, subscription agreement located at our main office. All data on this system is backed up weekly onto a tape drive, and is stored in an appropriately safe location.

BACK-UP OPERATIONS SITE

BOM will set up temporary office on a case by case basis when it deems it necessary and will communicate that location to employees. In the event that we are unable to access one of our primary facilities, it may be necessary to relocate certain personnel to the backup site. It is equipped with workstations that have redundant computer network connectivity, telephones, printers, fax machines.

PROTECTION OF PRIMARY FACILITIES

Protecting the infrastructure of our primary facilities is a high priority because it will allow the firm to continue operations in the event of many disaster situations, by permitting our employees to have access to and use of our facilities during that situation.