Freedom Investments, Inc., and BUYandHOLD, a division of Freedom Investments has developed a Business Continuity Plan (BCP) regarding our mission critical functions and how we will respond to events that may significantly disrupt our business. This disclosure is being provided to give you a summary detail regarding our risk mitigation strategy in the event of significant disruption to our daily business. Our plan is designed to allow us to continue to support all obligations to our clients. Our BCP and this disclosure are intended to comply with our obligations pursuant to regulatory rules and requirements as promulgated by the NASD.

Our plan anticipates two kinds of Significant Business Disruptions ("SBDs"), internal and external. Internal SBDs affect only our firm's ability to communicate and do business, such as a fire in our building. External SBDs that may prevent the operation of the securities markets or a number of firms including but are not limited to, a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD may rely on assistance from other organizations and systems, especially on the capabilities of our clearing firm as we attempt to restore our operating systems or some alternative that will enable us to accept and process customer orders and/or requests. Please be advised that orders and requests for funds may be delayed during this period.

Our BCP covers the following areas: mission critical systems, accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities, financial and operation assessments, alternative communications with customers, employees, clearing agent and regulators, alternate physical locations, data back up, regulatory reporting, dissolution plan if we are unable to continue our business and assuring our clients prompt and reliable access to their funds and securities.

Customers' funds are maintained at the Bank of New York Mellon and securities are maintained by our clearing firm and parent company, Oppenheimer & Co. Inc. ("OPCO"), which operates various offices throughout the country. Having locations that are not effected by the disruption(s) should help us to relocate our offices and employees. OPCO keeps appropriate records that are also appropriately backed up.

In the event of an internal or external SBD that causes the loss of our paper and hard copy records, we will attempt to physically recover them from our back-up files or records management facility. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location, as described above. For the loss of electronic records, we will attempt to either physically recover the storage media or electronically recover data from our back-up files records management facility, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.

We have and continue to evaluate various emergency situations and have designed multiple potential solutions to meet each circumstance. With that said, we recognize that our plan may not address unpredictable disasters and certain situations that may affect entities that we rely on for certain services. This BCP is subject to change without notice. In the event that the BCP is modified, the updated disclosure will be posted on our website at www.freedominvestments.com and www.buyandhold.com.