Pursuant to our fiduciary duty to our clients as well as client expectations, the Company has developed business continuity plans to respond to emergencies, disasters, and contingencies. The development and implementation of these procedures are designed to safeguard employee’s lives and Company property, make a financial and operational assessment, quickly recover and resume operations, protect the Company’s books and records, and allow our clients to transact business. In the event we determine we are unable to continue our business, we want to assure clients’ prompt access to their funds and securities.

These guidelines are designed to address two kinds of Significant Business Disruptions (SBDs). Internal SBDs affect only our Company’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of companies, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm or custodians.

CLIENTS’ ACCESS TO FUNDS AND SECURITIES The Company does not maintain custody of clients’ funds or securities, which are maintained at a custodial firm. In the event of an internal or external SBD, if telephone service is available, our representatives will continue to take or process client orders and contact the custodian for processing. If our website is available, the Company will post information on the website at www.woodlandssecurities.com or www.woodlandsassetmgt.com that clients may access their funds and securities by contacting the custodian and list their contact information. If you cannot contact us as you usually do, or you do not have internet access, you should call our alternative number at 713-806-4076. You may alternatively contact our custodial firms, Hilltop Securities ("HTS") at 214-859-1800 ( or www.hilltopsecurities.com) or Charles Schwab at 800-515-2157 (or www.schwab.com) directly. If the Securities Investor Protection Corporation ("SIPC") determines that we are unable to meet our obligations to our clients or if our liabilities exceed our assets in violation of SEC rules, SIPC may seek to appoint a trustee to disburse our assets to client accounts subject to SIPC regulation.

ALTERNATE COMMUNICATIONS We now communicate with our clients using telephone, e-mail, our website, fax, U.S. mail, and in person visits at our Company or at outside locations. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with clients. For example, if we have communicated with a client by e-mail but the internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail. If available, further information will be posted on our website. Alternate Contact information is also listed above.

VARYING TYPES OF SIGNIFICANT BUSINESS DISRUPTIONS (SBD)