Business Continuity

Business Continuity Planning ("BCP") was first initiated at RBS Greenwich Capital ("Firm") in 1991 and is an integral component of conducting and planning for all business at the firm. RBS Greenwich Capital is committed to maintaining a robust, comprehensive business continuity plan addressing a wide range of business interruption scenarios. The Firm's BCP team is comprised of senior personnel from the business and technology areas with oversight from the highest level of the Firm.

RBS Greenwich Capital's BCP is designed to meet the particular business needs associated with its activities. Those activities consist of institutional sales and trading of fixed income securities and related derivatives, and the asset-backed financing and securitization of consumer and commercial assets. As such, the focus of the Firm's BCP is on maintaining communication lines with its customers both telephonically and electronically, maintaining access to the fixed income markets both telephonically and electronically, and maintaining access to and authority over funds and securities held in the Firm's account at its clearing banks, or that are to be processed through the clearing organizations in which the Firm participates. RBS Greenwich Capital does not maintain custody of customer funds or securities.

The plan includes an alternate production site located approximately 40 miles from our headquarters which houses a production ready datacenter, with real-time data, software, and market prices, as well as trading and support workstations. Additionally, we maintain a command center in closer proximity to our headquarters to facilitate escalation procedures and provide more immediate access to systems. Our first line of defense against a business interruption, however, is maintaining a resilient infrastructure at our headquarters including generators, redundant power feeds, multiple telecommunications and data providers with dual access points to the building.
 
Our plan is tested a minimum of once per year, with key employees ensuring they can access mission critical systems and perform their required functions from our remote location. As our businesses change and grow, our plan is reviewed and revised as necessary to ensure complete coverage for businesses. In addition, as a wholly owned subsidiary of The Royal Bank of Scotland PLC ("RBS"), we participate in the planning, testing and review of RBS BCP procedures to ensure the global resilience of the entire bank. RBS Greenwich Capital also participates in industry wide planning and testing to assure that our regular operations as well as our BCP procedures are compatible with and perform in coordination with bank and securities clearing corporations BCP operations.

In the event of a disaster, the Firm is prepared and committed to continuing or resuming business within four hours, if feasible, to the extent that the fixed income markets in which it participates are open. The Firm will generally expect to adhere to the recommendations of the Securities Industry and Financial Markets Association regarding whether the fixed income markets should be open or closed on a particular day or time. If the fixed income markets are open, and the Firm is unable to adequately maintain the communications lines and access described above from its main headquarters, it will utilize a secondary remote location with:

   (1) real-time data replication to the site
   (2) alternate means of communications among employees, customers and  regulators, and
   (3) an automated emergency messaging service for employee and customer access.

If it is necessary to activate our remote location, employees will be asked to relocate to our disaster recovery site and resume operations. In the event we must evacuate our headquarters but cannot travel to our disaster recovery site, we will take measures to ensure that all trade settlement and liquidity requirements are met, and will prepare to open the next day at the remote site or at our headquarters.

In an emergency, our customers may access our website at www.gcm.com or call into our customer toll free number at 1-800-913-8196 for additional information. If you require additional information regarding our Business Continuity and Disaster Recovery procedures, you may contact Lawrence Skeats or Robert Wulff at (203) 625-2700.

Resources

In an emergency, our customers may access our website at www.rbsgc.com or call into our customer toll free number at 
+1 (800) 913-8196 for additional information.

If you require additional information regarding our Business Continuity and Disaster Recovery procedures, you may contact:

Lawrence Skeats or Robert Wulff at 
+1 (203) 625-2700