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Altegris Group of Companies: Business Continuity Planning

The Altegris group of companies is a group of financial services companies affiliated by virtue of common ownership and control (collectively referred to as the “Altegris Group”). Certain companies within the Altegris Group are subject to, and comply with, a variety of regulatory obligations with respect to their business continuity planning. Altegris Investments, Inc. (Altegris), a securities broker-dealer, and Altegris Clearing Solutions, LLC (ACS), a commodity trading advisor and introducing broker, are part of the Altegris Group, and are providing this summary. This summary is intended to generally outline the scope of the Altegris Group’s Business Continuity Plan (“Plan”), which addresses how we will respond to various events that could significantly disrupt our business, such as natural disasters, power outages and other extraordinary events. Since the timing and impact of such disruptions is unpredictable, our Plan has been designed to be flexible in its response to events as they may occur. The following highlights and summarizes our Plan.

Contacting Us

If after a significant business disruption you cannot contact us through normal channels, such as by phone at the La Jolla, CA office, (800) 828-5225 or (858) 459-7040, or our Evergreen, CO office at (888) 351-8485, you may also access the Altegris Group’s websites at www.altegris.com/alternative_investments.aspx, www.altegrisfunds.com and www.altegrismutualfunds.com. Alternate or temporary contact information will be provided on our website(s).

If you are unable to contact the appropriate Altegris company by any of the above means, you may contact other service providers in respect of your investments as follows:

For segregated managed futures account investments acquired through ACS (acting as an introducing broker for clearing firms), you should contact the clearing firm (i.e., in each case a futures commission merchant) where your specific account is held for information regarding account balances, trading levels, redemptions and wire transfers. Altegris currently introduces accounts at the following clearing firms:

For hedge fund or managed futures fund investments made through Altegris (acting as a selling agent for such funds), you should contact the general partner, managing member, trustee, sponsor or other manager of your fund investments directly with inquiries as to balances, redemptions or other requests. The contact information for each of your fund investments will appear on the periodic account statements sent to you directly by each fund.

For mutual fund investments made through Altegris (acting as a selling agent for such funds), you should contact Pershing, LLC, the clearing firm through which Altegris executes mutual fund orders. The contact information for each of your fund investments will appear on the periodic account statements sent to you directly by Pershing. You may contact Pershing directly to process limited trade-related transactions, cash disbursements, and security transfers. Instructions to Pershing must be in writing and transmitted via facsimile at (201) 413-5368 or by postal service as follows:

Pershing LLC
P.O. Box 2065
Jersey City, NJ 07303-2065
www.pershing.com

For additional information about how to request funds and securities when your financial organization cannot be contacted due to a significant business interruption, please visit the Customer Support section or call (201) 413-3635 for recorded instructions.

Our Business Continuity Plan

We intend to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and taking the necessary steps to allow our customers to continue transacting business as normal. In short, our Plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our Plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier/vendor, contractor, and bank impact; regulatory reporting; and assuring our customers have prompt access to funds and accounts held elsewhere if we are unable to continue our business.

With respect to segregated managed futures account investments, the clearing firm where each account is held maintains account records in a geographically separate area from where Altegris maintains duplicate account records for each such account of its clients. With respect to hedge fund or managed futures fund investments, the general partner, managing member, trustee, sponsor or other manager of each fund similarly maintains account records, in most cases in a geographically separate area, from where Altegris maintains duplicate account records for each fund investment made by its clients. With respect to mutual fund investments, Pershing maintains account records.

Types of Significant Business Disruptions

Significant business disruptions can vary in their scope, such as those (i) affecting only a single building housing our offices in La Jolla, California, Evergreen, CO, or any branch office of the firm, (ii) the business district or city sector where an office of the firm is located, or (iii) the entire city or region where an office is located. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In the event of a significant disruption, whether local or regional, we may transfer operations to another office or to an off-site location as necessary to recover and resume business operations as quickly as possible, in most instances within 24 hours. In that event, we will post notices on our website or by voicemail at our office phone numbers regarding how to contact the Altegris Group.

It is important to note none of the Altegris Group maintains custody of customers’ funds or securities. All funds are maintained with specific Critical Business Constituents, a list of which is maintained by the Altegris Group. If the significant business disruption is so severe that it prevents us from remaining in business, our customer’s prompt access to, and information about, funds and securities will continue to be available directly from the clearing firms, service providers, custodians, and third party funds that maintain customer assets.

More Information

If you have questions about our Plan, you may contact us by phone at (800) 828-5225 or by e-mailing us at compliance@altegris.com.