Business Continuity Planning

As a member of the financial services community, we, along with all of our peers, have developed a plan that will assure your ability to access your accounts, even if we are unable to continue operations. As one small piece of a complex, interdependent industry, we will make sure that we meet our responsibilities effectively, efficiently and with a coordinated speed that is derived only from proper planning. The financial services community has worked together in coordinating plans that assure operations are resilient and that the effects of disruptions in service are minimized in order to maintain public trust and confidence in our companies and financial institutions in general

True North has developed a Business Continuity Plan detailing 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

It is important to note that, as an introducing firm, we do not have custody of any assets. All of our customer's assets are held either at our clearing firm, Pershing LLC, a subsidiary of The Bank of New York Mellon Corporation, an investment company (such as American Funds or T. Rowe Price) or an insurance company (such as John Hancock). All of our clients receive statements, as least quarterly, which are issued by the company that holds your assets.

If, after a significant business disruption, you cannot contact us as you usually do, you should call our alternative number, 413-663-5353, or go to our web site at www.truenorthfs.com. If you have a brokerage or advisory account and cannot access us through either of those means, you should contact our clearing firm, Pershing LLC (www.pershing.com), a subsidiary of The Bank of New York Mellon Corporation, at (201) 413-3635/Fax (201) 413-5368 or, in writing at Pershing LLC. P.O. Box 2065 Jersey City, N.J. 07303-2065 for instructions on how you may process trades, disburse cash, or facilitate the transfer of your securities. On the Pershing website, click on "Business Continuity and Other Disclosures" at the bottom of the page, then click on the link to "Customer Support" that is provided within the text for specific instructions on how to contact Pershing directly to process trade-related transactions. There is also an alternate contact number for Pershing if you cannot access Pershing via the other previously noted telephone number. That number is (213) 624-6100, extension 500. For accounts other than brokerage accounts, please refer to your most recent statement for the direct telephone number for the investment or insurance company that holds your account. They can assist you in accessing your investments. You may also find contact information on their website if applicable.

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, Pershing LLC, backs up our important records in geographically dispersed facilities. 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 it's objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four hours. 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 those only affecting our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the entire region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption that only affects 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 four hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a self-contained alternative worksite contracted for through a vendor specializing in restoration of business operations or to a site outside of the affected area, and recover and resume business within 24 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm or other asset custodian if necessary, and notify you through our web site at www.truenorthfs.com or our customer emergency number, (413) 663-5353, about how to contact us. 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.

For more information

If you have questions about our business continuity planning, you can contact us at 413-664-4025.

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