Business Continuity Planning Customer Disclosure

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Revised 3/9/15

WR Hambrecht + Co (WRH+Co) has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us: If after a significant business disruption you cannot contact us as you usually do at our San Francisco Office (415) 551-8600, our New York Office (212) 313-5900, and our Mill Valley Office (415) 888-3285 you can also go to our web site at www.wrhambrecht.com.

If you cannot access us through those means, you should contact the appropriate clearing firm. If your account is at RBC Capital Markets (RBC), to process limited trade-related transactions, cash disbursements, and security transactions, please contact them at (800) 949-0242 or postal service: RBC Plaza, 60 South 6th Street, Minneapolis, MN 55402-4422. If your account is at APEX, to process limited trade-related transactions, cash disbursements, and security transactions, instructions to Apex must be in writing and transmitted via fax (214) 765-1100 or postal service: Apex Clearing Corporation: 1700 Pacific Ave., Ste. 1400; Dallas, TX 75201. Please note that the fax number listed is for business interruption-related issues only. Information received on this fax that is unrelated to business interruption issues will not be acted upon.

Apex will only process a sale of a security held long in the account or a buy to close-out a short security position. Market orders will only be accepted. Written trade-related instructions must include your account number, account title, type of transaction, security symbol or CUSIP number, number of shares and all account holder signatures. Written cash disbursement instructions must include your account number, account title, amount to disburse, all account holder signatures, and method of disbursement: check (include the name and address of account holder) or wire (include the bank name, ABA number, and receiving bank account number). Third party disbursement transactions will not be accepted during this time. Written securities transfer instructions must include your account number, account title, security symbol or CUSIP number, all account holder signatures, and method of transfer . Internal Apex transfer (include the receiving account number, account name and account address) or DTC (Include the receiving financial organization, DTC number and receiving account number).

Our Business Continuity Plan: We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our Business Continuity Plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firms back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments within the same business day. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions: Significant business disruptions can vary in their scope, such as only our firm, a 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 within 2 business days. 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 within 2 business days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you how to contact us through our web site www.wrhambrecht.com or our customer emergency numbers in San Francisco (415) 551-8600 and New York (212) 313-5900 and Mill Valley (415) 888-3285. If the significant business disruption is so severe that it prevents us from continuing to conduct business, we will assure our customer’s prompt access to their funds and securities.

For more information: This plan is subject to modification and an updated plan will be promptly posted on this site. Customers may alternatively obtain updated summaries by requesting a written copy by mail. If you have questions about our business continuity planning, you can contact us at 909 Montgomery Street, 3rd Floor San Francisco, CA 94133 (415) 551-8600 or at www.wrhambrecht.com.