KBIS Capital (“KBIS”) maintains a business continuity plan designed to minimize significant business disruptions and allow for the restoration of critical resources should access to our offices or systems become unavailable. This plan identifies mission-critical processes and provides for their recovery in the event of various types of business interruptions. This plan is continually evaluated and amended as necessary to ensure that the impact of any business interruption is minimized.

KBIS has chosen to provide this Summary Disclosure via e-mail upon either a verbal or written request. It is important to note that KBIS’ BCP is subject to modification. Upon any such modification, an updated Summary Disclosure will be posted immediately on the firm’s website. Customers may also receive such updates by mail upon written or verbal request.

KBIS realizes the importance of providing uninterrupted business regardless of adverse conditions and has enacted procedures to ensure the services and support systems necessary to meet all existing obligations. We believe that our plan adequately identifies and eliminates business continuity risk associated with various types of significant business disruptions (whether firm only, single building, business district- wide, citywide, or region-wide).

Provisions for financial and operational assessment are in place to insure the quick recovery and resumption of operations, as well as protection of all of the firm’s books and records. Designated emergency contact persons for KBIS oversee KBIS’ emergency backup systems. Included in these are systems for electronically backing up and storing data. Also, a cloud based off-site location is utilized for storage of electronic copies of books and records. As to KBIS employees, contact lists for all KBIS employees are kept current. KBIS has various methods for contacting our employees and all employees will be able to meet at our designated backup location.

In the event of a significant business disruption, KBIS customers are assured that they will have prompt access to their funds and securities. Our firm provides advisory and consulting services does not perform any type of clearing function for itself or others. We do not directly hold customer funds or securities

In the event of a significant business disruption, KBIS will move our operations to our designated backup/recovery site. Necessary business tools, such as computers, phones, etc. are kept at our backup site and will be tested annually. Details pertaining to the location of our backup facility, any existing arrangements, any individuals with whom those arrangements have been made and other details cannot be disclosed for security reasons.

In the event of a significant business disruptions, our website www.kbiscapital.com will contain alternate telephone numbers for both KBIS and our custodian in order to provide clients access to their account.

Though KBIS is cognizant of the fact that no BCP is perfect, we have done our best to accomplish our goal concerning this issue. This BCP is subject to change without notice. If material changes are made to KBIS’ BCP, an updated disclosure will be distributed via email.