Business Continuity Executive Summary

Willow Cove Investment Group, Inc.

Willow Cove Investment Group’s Business Continuity Plan

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, 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 the firm will continue its order taking, order entry, and forwarding requests for checks and securities to our clearing firm RBC Capital Markets, LLC. If RBC Capital Markets, LLC experiences 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 will work with clients to assure access to their funds and securities.

Firm-only Business Disruption

In the event of an SBD that affects only Willow Cove the firm will attempt to transfer operations to another facility, and Willow Cove anticipates that mission critical systems would be recovered from an alternate location. The resumption objective for mission critical systems would be a four-hour recovery time, and a resumption time of business operation would be within the same business day. During this process, clients may experience delays in reaching the firm.

Business–District, Citywide, or Regional Disruption

In the event of an SBD that affects the central business district, city, or region where Willow Cove’s mission critical functions are located, the firm will transfer operations to another facility outside of the affected area. The resumption objective for mission critical systems would be a four-hour recovery time,and a resumption time of business operations would be within the same business day. During this process, clients may experience delays in reaching the firm.

For any questions regarding this summary, please contact the following persons:

Michael W. Losse, PresidentWillow Cove Investments Group, Inc.

(858) 404-0677 4370 La Jolla Village Drive Suite 400

an Diego CA 92122

Herbert L. Horen, Vice President(858) 404-0677

(858) 404-0677

UPDATED: 11/30/2010