Business Continuity Planning

M.S. Howells & Co. has developed a Business Continuity Plan on how we will respond to events that could 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 in regards to our business continuity plan.

Contacting Us: If we experience a significant business disruption and you cannot contact us at (480) 563-2000, you should call our alternate customer emergency number (602) 619-5750 or go to our website at www.mshowells.com. If you cannot access us through either of those means, you should contact our clearing firm, Jefferies & Company, Inc. ("Jefferies") at (877) 400-9595 or (201) 761-7600 for instructions on how you may execute orders for your account(s), obtain access to your funds or securities, or request funds.

Our Business Continuity Plan: We plan to quickly recover and resume business operations after any significant business disruption. We will 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 the 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 firm, Jefferies, backs up our important records in a geographically separate area and has their own Business Continuity Plan. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, Jefferies has advised us that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within a reasonable period of time. 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 as needed and expect to recover and resume business within 24 hours. 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 48 hours. In either situation, we plan to continue with our business or, if necessary, transfer our operation off site. Customers will be notified through our website www.mshowells.com or our customer emergency number, (602) 619-5750 regarding how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

For more information: If you have questions about our business continuity plan, please contact us at (480) 563-2000.