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BUSINESS CONTINUITY PLAN

Third Lake Associates, LLC (“we” or the “Firm”) 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 be flexible in responding to actual events as they occur. The Firm plans to quickly recover and resume business operations after a significant business disruption (“SBD”) and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the Firm’s books and records, and allowing our investors and customers (“customers”) to transact business. In short, our Firm’s business continuity plan (“BCP”) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD.

 

The Firm’s BCP addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, registered persons and regulators; alternate physical location of registered persons; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their customer information including information about their funds and securities.

 

Issuers of private placed unregistered securities you own also maintain all records related to your investments and account holdings and should back up important records in accordance with their business continuity plan. For more information on their contingency plan, please contact the issuer directly at the telephone number provided on your offering documents or through their website.

 

Significant Business Disruptions

Significant business disruptions can vary in their scope, such as only our Firm’s office or building, 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. The Firm’s plan takes into account two kinds of SBDs, internal and external. Internal SBDs affect only the Firm’s ability to communicate and do business, such as a fire or loss of electrical power in the office or building where the Firm is located. External SBDs prevent the operation of the securities markets or a number of firms or a larger geographic area, such as a natural disaster or large blackout, or another event that causes a wide-scale, regional disruption in essential services.

 

Internal SBDs

In the event of a disruption in the Firm’s business operations due to an internal SBD, the Firm will attempt to continue to conduct business as usual generally by (i) utilizing alternative communication methods (as available), such as cell phones, email and Zoom meetings, (ii) by moving its operations to an alternative physical location and/or (iii) by having some or all registered persons operate from their residences, or any combination of the foregoing.

 

External SBDs

In the event of a disruption in the Firm’s business operations due to an external SBD, the Firm will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the effected area, if possible, or by taking the same or similar steps above as with an internal SBD.

 

Depending upon the specific circumstances of the internal or external SBD, and what steps the Firm may take, (i) there may be a delay in resuming operations, (ii) as soon as practicable, the Firm will seek to provide customers with relevant information, including about the status of the Firm’s operations and customer investments, and (iii) the Firm will attempt to resume business generally within 24-48 hours.

 

In all cases, the Firm will resume normal business operations as soon as it is reasonably able to do so, based on the type and the extent of the disrupting event.

 

If the significant business disruption is so severe that it prevents us from resuming business operations for an extended, long period, the Firm will apprise customers of that fact and other relevant events and appropriate next steps, if and as applicable.

 

Communications

If after a significant business disruption, you cannot contact us as you usually do, please contact the Firm at the following telephone number: 727-349-9300.

 

Contact information

Any questions regarding the Firm’s Business Continuity Plan should be addressed to: contact@thirdlakeassociates.com or 727-349-9300.

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