Business Continuity Plan Disclosure Statement for Karbone Capital Markets, LLC

Karbone Capital Markets, LLC (the “Firm”) maintains a comprehensive Business Continuity Plan that sets forth how we will respond to events that significantly disrupt our business. The Firm maintains all of its files and records in various cloud services that provide file backup. The company’s business can be resumed from any location with internet access. Some individuals registered with the firm work remotely already.

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 about our Business Continuity Plan.

Account Files and Corporate Records

All Firm records are maintained in cloud storage using the Google Cloud service. Google Cloud is accessible from the devices of each registered individual. Web access is also available. Specific folder access is limited to each registered individual on a need-to-know basis.

Email

The company uses a Google cloud-based email service Gmail. Google operates data centers around the U.S. that provide full redundancy. The email service can be accessed from any location with the devices of any of the registered individuals, as well as through webmail.

The company archives its email using service provider Global Relay. This is also a web-based service.

Telephones

The auto-attendant on the company’s main line can forward calls to the phone of any of the registered individuals. The company can also re-assign the direct dial numbers to any phone.

Employee Notification

Dave Prunier has contact information for all registered individuals. In the event of any actual disruption Prunier will communicate with each other, then contact the registered individuals.

Contacting Us

If after a significant business disruption you cannot contact us as you usually do at (646) 291-2900, you also may reach Dave Prunier at (845) 325-5374. In the event of an internal or external SBD, if telephone service is available, our registered persons will communicate with customers, via email.

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 backup 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 counterparty impact; regulatory reporting. The Firm does not hold customer funds or securities. These are transmitted directly from the customers to the issuers.

Varying Disruptions

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, the employees of the Firm will work remotely from their homes. In a disruption affecting our business district, city, or region, the employees of the Firm will work remotely from their homes to the extent possible. In either situation, we plan to continue in business and we will immediately identify what means will permit us to communicate with customers, employees, critical banks, critical counter-parties and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ can include our website, telephone voice mail, cellular phone, secure e-mail and any other means which may become available.

For more information, or If you have questions about our business continuity planning, you can contact us at 
(646) 291-2900 or accounting@karbone.com