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For operations relating to clearing and settlement, the Business Continuity Plan of RBC Capital Markets, LLC (“RBCCM LLC” or the “Firm”) applies:

Business Continuity Plan of RBCCM LLC

To our Clients and Prospective Clients:

RBCCM LLC is committed to protecting its employees, clients and their assets at all times, including during emergencies or significant business disruptions. The Firm’s Enterprise Business Continuity Program has been developed to provide a reasonable, but not absolute, assurance of business continuity in the event of a disruption to the Firm’s normal operations.

As part of this commitment, and in compliance with internal policies and industry regulations, the Firm has developed and implemented Business Continuity Plans (the “Plans”) for its business units. Each Plan is developed by identifying each business unit’s critical risks and documenting the functional requirements needed to reestablish essential business operations. The Plans document the actions and procedures to be followed before, during, and after a prolonged service outage resulting from the loss of operational facilities, critical information systems, or essential personnel. In instances by which business processes require recovery from a significant operational disruption, the Plans include off-site recovery environments, work-area displacement agreements, and/ or work-from-home arrangements.

The Firm conducts annual disaster recovery exercises, designed to ensure computing systems and networks are built with sufficient redundancies. The Firm also requires all business units conduct an annual contact exercise to ensure personnel, particularly recovery team personnel and their alternates, can be contacted at any time, on short notice. In addition, Plans are tested throughout the year in an effort to ensure that the Firm and its clients are provided with a recovery solution most conducive to their needs.

The Firm relies on the availability, capacity, and reliability of information technology. Each primary computer center has a corresponding back-up/disaster recovery site that is established away from the Firm’s primary facilities. The Firm’s computer centers are equipped with stand-alone electrical power and cooling capabilities sufficient to run for several weeks without relying on utility power. In an effort to ensure that applications are restored within a period of time acceptable to the business, applications have been prioritized, and their recovery requirements are based off of that prioritization.

The Firm’s incident management team is responsible for the coordination of communication and response procedures in the event of a disruption or possible disruption to normal operations. Included in the incident management team’s responsibilities is the communication of the Plans with regulatory agencies and key business partners. Members of the incident management team, and its procedures and protocols, have been documented in the Plans.

Pertinent updates to this disclosure statement will be posted on the Firm’s websites, as required by applicable law or regulation. Hard copies of the disclosure statement can be obtained by contacting your representative of the Firm.

The Plans are confidential and proprietary in nature and are therefore not made available for public distribution.


Other Business Continuity Considerations relating to the MuniAxis Trading Platform

For activities relating to the MuniAxis trading platform:

The MuniAxis trading platform is hosted away from the Firm’s primary facilities in a secure hosting facility.  The platform is designed and configured for high availability, supported on a 24x7x365 basis by operations personnel and equipped with continuous monitoring and auxiliary electrical power.  There is no off-site disaster recovery site capability for this platform.  In the event of a significant technology issue related to the MuniAxis trading platform, the Firm would make a determination of whether to cease trading activities on the platform until the issue is resolved.