Business Continuity Plan

CBIS’ business continuity plan is designed to create a framework in which to effectively and resiliently respond to a significant business disruption. During a business disruption event, CBIS will seek to safeguard the interests of its participants, its employees’ lives and CBIS’ property. CBIS will do so by making a financial and operational assessment and seeking to quickly recover and resuming normal operations, protect its books and records and data, and allow participants to transact business.

CBIS’ plan anticipates two kinds of significant business disruptions internal and external. Internal disruptions would affect only CBIS’ ability to communicate or do business, such as a fire in one of our offices. External disruptions would prevent the operation of the securities markets or a number of firms, and include a terrorist attack, a city flood, or a wide-scale regional disruption. CBIS’ response to an external disruption relies more heavily on other organizations and systems, especially on the capabilities of local police and fire departments and on our master custodian and other custodians chosen by participants.

The CBIS business continuity plan outlines procedures the firm will take for: 1) total destruction or inaccessibility of an office; 2) damage to, or theft of, critical phone equipment or computer hardware; 3) partial destruction of an office or equipment; 4) loss of paper files; 5) power failure; 6) fire; and 7) loss of key staff via sudden death or other calamity. CBIS operates offices in Chicago, IL and New York, NY. In the event of total destruction or inaccessibility to one of our offices, we will either move employees to one of our other offices or work remotely from their residence or a temporary location. Steps are in place to retrieve all necessary account information, operating systems and equipment, to redirect phone calls and mail, and to notify banks, asset managers, vendors and suppliers. CBIS does not anticipate that the destruction or inaccessibility of one of our offices will halt our ability to do business. If all three offices were destroyed or made inaccessible simultaneously, CBIS would strive to resume operations within twenty-four hours from its temporary office space.

This plan is subject to modification. As the plan is modified, an updated summary will be posted on the CBIS website. Participants may also obtain the current summary and any updates by requesting a written copy by mail.