Business Continuity Plan

Spouting Rock Financial Partners LLC has developed a business continuity plan (BCP) on how we will respond to significant business disruption (SBD) events. 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 on our business continuity plan.

We plan to quickly recover and resume business operations after a 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 customers to transact business. In short, our BCP is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the SBD.

Our BCP addresses data backup 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.

The placement issuers maintain all records related to your investments and holdings and backs 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 or offering documents or through their website, if applicable.

Significant Business Disruptions

The Company’s plan 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 and mobile phones, 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 with 4-6 hours.

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 customers with alternative communication arrangements, as indicated below, to conduct business or to access their funds and securities. The Company will attempt to resume business within 24 hours and to keep its customers 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 customer’s prompt access to their funds and securities.

Communications

In the event you are unable to contact us as you usually do at our direct dial or mobile numbers for firm staff, or email to firm staff, you should proceed as follows:

  1. Contact the Company at our main telephone number: 610-788-2128
  2. Access the Company’s website at www.spoutingrock.us
  3. Contact the private placement issuer directly at the number listed on applicable offering documents.
  4. Access the issuer’s website for more information on contacting this entity and their business continuity plans. The website address can generally be found on your offering documents.
  5. Contact FINRA’s District office at the following telephone number for more information on the company’s status and additional instructions: 215-665-1180

Contact information: Any questions regarding the Company’s Business Continuity Plans should be addressed to: Director of Operations, Spouting Rock Financial Partners LLC, 100 Matsonford Road, Five Radnor Corporate Center, Suite 440, Radnor, PA 19087.

Updated: June 2013