Business Continuity Planning – Disclosure Statement

Introduction

The Business Continuity Planning Disclosure Statement summarizes Raymond James (the Firm) effort to mitigate risks inherent with unforeseen business interruptions. Raymond James institutes best practices developed by industry organizations for creating practical and effective business continuity plans. Processes are developed with business continuity in mind, embedding the necessary resources and knowledge into our day-to-day operations.

Organization

Raymond James has established the Business Continuity Planning (BCP) department, a dedicated team of professionals that oversees the Firm’s business continuity management strategy. The BCP Department works closely with business units and the Information Technology Department to employ a standardized framework for building, maintaining, and testing business continuity plans. The plans are created using an all hazards approach, including baseline requirements and strategies that address incidents of varying scope.

Plans are designed to allow for continued operations of critical business functions, which include providing clients with prompt access to their funds and securities.

Incident Management

A Corporate Crisis Management Team (CCMT) comprised of senior management representing key areas of the Firm has been established to manage incidents that might impact the Firm’s associates and clients. The CCMT will assess and direct the Firm’s response to an incident, ensuring the safety and security of all associates and continuity of critical processes.

As part of the overall BCP strategy, Raymond James maintains geographically dispersed operational locations to diminish risks posed by local and regional disruptions. In the event of an emergency at the home office, local staff is available at off-site locations to continue production work.

In the event of a disruption, communications will occur in several ways. General information, such as incident updates, office closures, and operating hours will be available to associates on the Firm’s internal Website. In addition, associates will call the Raymond James emergency telephone hotline to obtain similar updates. Consistent and timely messages will be disseminated to associates, clients, business partners, regulators and the media.

Technology and Data Recovery

Raymond James employs a dual data center strategy in which critical client data and systems are replicated to an alternate location ensuring accessibility. In addition, data retention and backup procedures are in place, including tape backup and offsite storage, offering a tertiary layer of data accessibility should the need arise.

It is the Firm’s goal to recover from an event requiring a processing switch to the alternate site within 12 hours or less.

Contacting Raymond James

In the event of a business disruption, clients can obtain information regarding the status of their accounts and access to their funds and securities by contacting their financial advisor. If their financial advisor is unavailable, clients can contact Client Services at 1-800-647-7378. In addition, up-to-date information regarding the operating status of the Firm can be obtained from www.raymondjames.com.

Disclaimer

Due to the unpredictable nature of events causing significant business disruptions, the Firm cannot guarantee that systems will always be available or recoverable after such events. Additionally, the Firm’s business continuity plans are subject to modification.

Statement Availability

This BCP Disclosure Statement, including any updates or amendments, is available at www.raymondjames.com/business_continuity_planning.htm. Hard copies of the BCP Disclosure Statement can be obtained upon request by contacting your Raymond James representative.