Business Continuity Plan Summary

One 2800 Capital Advisors, LLC

One 2800 Capital Advisors, LLC (the “Company”) 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 clients to transact business. In short, our company’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 BCP 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 clients prompt access to their funds and securities if we are unable to continue our business.

Our custodian bank backs up our important financial 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 custodian bank that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments within a resumption time period. Your transactions could be delayed during this period.

Significant Business Disruptions. The Company’s BCP takes into account two kinds Significant Business Disruptions, internal and external. Internal SBDs affect only the Company’s ability to communicate and do business, such as a fire or loss electrical power in the office or building.

External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services.

Internal SBDs. In the event of a disruption in the Company’s business operations due an internal SBD, the Company will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving its operations to an alternative location.

If personnel or operations must be moved to an alternate location, the Company anticipates that it will resume regular operations as soon as personnel can access the alternate site.

External SBDs. In the event of a disruption in the Company’s business operations due to an external SBD, the Company 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 providing clients with alternative communication arrangements, as indicated below, to conduct business or to access their funds and commodity interests.

The Company will attempt to resume business and keep its clients informed regarding relevant events to the best of its ability based on the circumstances.

In all cases, the Company will resume normal business operations as soon as it is 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 remaining in business, we will assure our clients’ prompt access to their funds and securities.

Communications. In the event you are unable to reach the Company at our main number, please proceed as follows:

· Contact the Company at the following email address: jloughmiller@blueandco.com.

Contact Information

Any questions regarding the Company’s Business Continuity Plan should be addressed to: Jarit T. Loughmiller, One 2800 Capital Advisors, LLC, 12800 N. Meridian Street, Suite 400, Carmel, Indiana 46032, (317) 275-7426.