Business Continuity Plan Disclosure

The CenterCap Group, LLC and its affiliates has established a Business Continuity Plan (“BCP”) that details how we will respond to events that significantly disrupt our business and provide continuity of critical business functions. Consistent with regulatory requirements, this disclosure statement is designed to provide you with a summary of how we intend to respond to such events. Due to the proprietary nature of some information, detailed plans for the program cannot be publicly disseminated.

Contacting The CenterCap Group, LLC or any of its affiliates In the event of a significant business disruption, please contact us at (212) 620-2655 to receive information relating to the business disruption. Within the scope of our ability at the time of an incident, we will notify first our Senior Leadership and then our other employees who will be notified to enact our Business Continuity Plan..

Business Continuity Plan The BCP begins with an assessment of all aspects of CCG’s key business functions and a method for recovery. The plans are reviewed and updated annually, or as significant business changes occur. The BCP is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. The BCP has been specifically designed to safeguard the interests of our clients. Our BCP also intends to secure the safety of our employees. Included in our BCP are steps to assess and recover the following: data; mission critical systems; financial and business operations; and communications with employees, clients, banks, regulators and other business constituents.

Varying Disruptions While CCG’s BCP has been designed to allow the firm to operate during emergency incidents of varying scope, such potential incidents are unpredictable. The firm has no control over certain infrastructure such as communications networks and transportation that we may rely upon during an emergency. Because of the unpredictable and unknown nature of a potential business disruption, CCG cannot presently guarantee how it will respond precisely in the future; however, the scope could impact only our firm, the single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only 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. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business. In either situation, we plan to continue our business operations the next day.

Updates As company and industry conditions change, we will continuously revise our BCP as considered necessary. Any updates to this disclosure summary will be promptly made available on our website. Alternatively, you may obtain the most current disclosure summary by requesting a written copy by mail at: The CenterCap Group, LLC, 1540 Broadway, 10th Floor, New York, NY 10036.

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