Willow Cove maintains a business continuity plan (BCP) intended to assist the firm in responding to significant business disruption, such as from fire, flood, earthquake, terrorism, pandemic, etc., by attempting to safeguard employees’ lives and firm property; make a financial and operational assessment; quickly recover and resume mission critical operations; protect the firm’s books and records; and allow clients to transact business as smoothly as possible. Nevertheless, there are some disruptions that may render the firm unable to continue business.

If Willow Cove experiences an SBD, generally our firm processes transactions/orders by recording them on paper and electronically sending them to our sponsors or selling groups or alternatively telephonically. The firm will continue forwarding requests for checks to our sponsors. If our sponsors experience an SBD that prevents them from continuing in business, then Willow Cove could not continue in business. The firm has also arranged to address the impact of an SBD on critical- business constituents, banks, and counter-parties.

In the event of an SBD that causes the firm to invoke its BCP, Willow Cove will notify its clients. If Willow Cove is unable to execute its BCP in a timely manner, the firm will assist its clients in seeking services from an alternate source.

In addition, Willow Cove will advise clients of any material changes to its BCP that may affect the ability of Willow Cove to continue its operations. In the event that it is determined that the firm is unable to continue business, Willow Cove will work with clients to assure access to their funds and investments.