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IMPORTANT DISCLOSURES

Business Continuity Plan

Disclosure to Clients and Investors

Cohen Asset Management, Inc. ("CAM") maintains a Business Continuity Plan ("BCP") that provides a course of action for the assessment of a significant disruption to business and for the continuation of business following such an event. The BCP consists of company-wide and departmental disaster recovery plans and includes the formation of the CAM Incident Management Team ("IMT"). The IMT would serve as the central source of coordination and communication in the event of a significant disruption to our business. During such an event, the IMT would first ensure the health and safety of our employees, and would then oversee the re-establishment and continuation of business processes pursuant to the BCP. The IMT is responsible for evaluating the disruption, instituting the appropriate plan of action, and coordinating recovery efforts.

The BCP is designed to address significant business disruptions of varying scope including, but not limited to:
  • CAM-only business disruption
  • Disruption to a single building in which CAM business is conducted
  • Disruption to a business district in which CAM business is conducted
  • City-wide business disruption
  • Regional disruption
  • National disruption
In each of these scenarios, CAM's BCP provides for an evaluation of the scope of the business disruption, and sets forth various plans of action and recovery facilities for the continuation of the firm's business, as well as, alternative means for the dissemination of information to employees and clients and investors. The BCP serves as a guide that addresses how CAM will continue to conduct business during each of the above scenarios, to the extent that is possible pursuant to the IMT's evaluation.

It is CAM's intention to minimize the recovery time necessary to resume operations. CAM conducts regular testing of the recovery of its back-up facilities and systems in order to ensure clients and investors will be able to access their information within a reasonable time following a significant business disruption. Clients and investors should be assured they will have prompt access to their information through CAM's back-up systems.

The BCP is subject to modification based on changing circumstances and assessment of need.
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