Business Continuation Summary

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It is the policy of Janney Montgomery Scott LLC (“Janney”) to respond to a Significant Business Disruption (“SBD”) by safeguarding employees’ lives and Firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and allowing Janney customers to transact business.

To that end, Janney has established a Business Continuity Plan (“BCP”). Janney’s BCP includes redundant data centers and alternate processing facilities, to address interruptions to its normal course of business. Janney’s BCP anticipates two kinds of SBDs, internal and external. Internal SBDs, such as fire or power outage in Janney’s building, affect only Janney’s ability to communicate and do business. External SBDs, such as terrorist attack, city flood, or wide-scale regional disruption, prevent the operation of the securities markets and/or the operation of a number of brokerage firms.

Janney’s objective is to recover its mission critical systems and continue business within (6) hours for business systems. Personnel relocation might take an additional (2) hours. Recovery time objectives are not hard and fast deadlines to be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure - particularly telecommunications - can affect actual recovery times. Janney’s BCP also includes relocation of critical personnel to an offsite facility and the automatic forwarding of telephone lines from the affected locations to the relocation site.

The plan is subject to modification, an updated summary will be promptly posted on Janney’s website. Janney will provide a copy of the summary upon written request.