Business Continuity Plan Summary

Schmitz Capital Partners has established a business continuity plan (“BCP”) to guide the Firm’s responses to unforeseen events that could cause temporary interruptions of its business. Schmitz Capital Partners does not custody customer accounts. Schmitz Capital Partners does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, Pershing LLC. If there is an interruption at Schmitz Capital Partners, customers with clearing concerns should contact our non-affiliated Broker-Dealer, Royal Alliance Associates, Inc. and/or our clearing firm, Pershing LLC. The Royal Alliance toll-free office number is 1-800-821-5100. James Bogdan, a Managing Executive for Royal Alliance Associates, Inc., can be reached at 949-261-8630 x113 and will take customer orders or instructions and contact our clearing firm, Pershing LLC, on their behalf. In the event of an internal or external SBD, our clearing firm, Pershing LLC, 1 Pershing Plaza, Jersey City NJ 07399, can be contacted directly at 201-413-2000, or at www.pershing.com.

Under our BCP Schmitz Capital Partners duplicates all critical Firm, client, regulatory and financial information on appropriate media, and stores the backed-up information at remote locations. Such information is regularly sent or uploaded to off-site storage facilities. From time to time Schmitz Capital Partners participates in disaster recovery exercises to confirm that such stored information remains accessible to it, and accurate. Among other things, Schmitz Capital Partners also secures and monitors its data center, regulates its data communication lines and maintains and supervises password policies and procedures to limit access to its data. Procedures are in place to notify employees if an event results in a change in business locations or processes, although a business-wide disruption could temporarily delay the processing of information and requests. Provisions have also been made for clients to continue to be able to contact SCP employees. Updates to clients will either be posted on our website www.schmitzcapital.com or sent via e-mail and regular mail in the event of a disruption.

Business continuity planning is an on-going process, and Schmitz Capital Partners currently is evaluating a number of initiatives to improve its disaster response time. It regularly evaluates additional business continuity plan opportunities. Schmitz Capital Partners appreciates your continued business as together we attempt to anticipate and plan for uncertainties in an uncertain time.