Business Continuity Plan – Cohen & Company

BUSINESS CONTINUITY PLAN

Cohen & Company Inc.’s (“Cohen & Company”) business continuity plan (“BCP”) covers the operations of its broker-dealer, J.V.B. Financial Group, LLC (“JVB”), as well as the rest of the Company, including Cohen & Company’s asset managers (Cohen & Company, together with its subsidiaries, is referred to as the “Company”). The Company is committed to providing reliable, trustworthy service that represents the best interests of its clients. The Company has developed a BCP to protect its clients and employees in the event of an emergency or significant business disruption. The BCP is designed to recover and resume business operations as soon as possible after a business disruption, and respond by safeguarding the Company’s employees and property, making a financial and operational assessment, protecting the Company’s books and records, and allowing the Company to transact business. In short, the Company’s BCP is designed to permit the Company to resume operations as soon as possible, given the scope and severity of the business disruption.

The Company’s BCP addresses: data back-up and recovery; mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternative physical location of employees; critical suppliers, contractors, bank and counter-party impact; and regulatory reporting.

The Company’s electronic records are backed-up on a daily basis and these records are maintained in a separate location.

Every emergency situation poses unique problems based on external factors, such as time of day, location and severity of the disruption. In the event of an emergency situation preventing access to or resulting in the loss or destruction of, the Company’s main computer hardware system and/or its servers located in the Company’s main office located at 1633 Broadway, 28th Floor, New York, NY, and/or the data housed thereon, the Company anticipates that, once it has procured the necessary hardware, it may take approximately five (5) business days to rebuild and restore the system and/or servers in order to read the off-site back-up devices.

Business disruptions can vary in their scope, such as a disruption only to the building housing the Company’s main office or one of its other offices, the business district where the Company’s main office or one of its other offices is located, the city where the Company’s main office or one of its other offices is located, or the whole region in which the Company’s main office and/or one of its other offices is located. Within each of these areas, the severity of the disruption can also vary from minimal to severe.

Whether a disruption affects the Company or a building housing one of the Company’s offices only or the relevant business district, city, or region, the Company’s employees will either work at remote location(s) and/or the Company will transfer some or all of its operations to an unaffected alternate available site(s) where the Company would expect to recover and resume business as soon as possible. In any business disruption, the Company plans to continue in business and plans to resume normal operating activities as soon as possible. In any business disruption, the Company will attempt to notify you by telephone or other available communication means about how to contact the Company.

In the event that you are unable to reach the Company’s broker dealer subsidiary, JVB, you may contact JVB’s clearing firm, Pershing, LLC directly to process limited trade-related transactions, cash disbursements, and security transfers. Instructions to Pershing must be in writing and transmitted via facsimile or postal service as follows:

Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065
Fax: (201) 413-5368

For additional information about how to request funds and securities, please refer to the information below or call (201) 413-3635 for recorded instructions. If you cannot access the instructions from the previously noted telephone number, Pershing may be contacted at (213) 624-6100 extension 500 as an alternate telephone number for recorded instructions. Please visit www.pershing.com for further information.

The specific transactions Pershing will perform for clients of JVB, and the required accompanying information, are as follows:

Trades

Pershing will process the following closing security transactions:

Sale of security position held long in the client’s account
Buy of security to close-out short security position

Pershing will process closing security transactions upon receipt of written instructions that must include the following information:

Client brokerage account number
Client name (as registered on the brokerage account)
Security description, including symbol or CUSIP® number
Number of shares. NOTE: All orders will be handled as market orders.

Cash Disbursements

Pershing will process cash disbursements upon receipt of signed written instructions that must include the following information:

Client brokerage account number
Client name (as registered on the brokerage account)
Exact amount to be disbursed
Indicate method of disbursement (as follows) and provide the information indicated:
1. Check (payable to account name only).
  - Indicate name and address of record check is to be mailed to
2. Federal funds.
  - Indicate receiving bank name, ABA number, and receiving bank account number. NOTE: The receiving bank account name and brokerage account name must be identical unless we have a letter of authorization on file indicating alternate instructions.

Securities Transfers

Pershing will process security transfer requests upon written instructions that must include the following information:

Client brokerage account number
Client name (as registered on the brokerage account)
Description of security(ies) to be transferred, including symbol(s) or CUSIP number(s)
Quantity to be transferred
Receiving account information for securities, as follows:
1. Transfer to another brokerage account at Pershing
  - Provide receiving account number at Pershing (name and address on both accounts must be the same)
2. Transfer to another financial organization
  - Name of the receiving financial organization
  - DTC number (if the receiving financial organization is a registered broker-dealer)
  - Account number at the receiving financial organizationPrivacy/CIP Notice

For more information – If you have questions about our BCP, you can contact:

Stephan Burklin
Chief Operating Officer
J.V.B. Financial Group, LLC
1825 NW Corporate Blvd
Ste 100
Boca Raton, FL 33431
e-mail: sburklin@jvbfinancial.com
T: 561-939-1214