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Business Continuity Plan and Client Disclosure Statement

TRISTONE CAPITAL (U.S.A.), INC.
TRISTONE CAPITAL CO.

Business Continuity Plan

Client Disclosure Statement

Tristone Capital (U.S.A.), Inc. and Tristone Capital Co. have developed Business Continuity Plans on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plans.

Please be advised that National Bank Correspondent Network is the clearing firm for Tristone Capital (U.S.A.) Inc. Pershing, LLC is the clearing firm for Tristone Capital Co.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do at (403) 294-9541/ggosbee@tristonecapital.com or (303) 952-2800/mkehler@tristonecapital.com, you should call our alternative number (403) 287-6571, (403) 615-2232 or go to our web site at www.tristonecapital.com. For Tristone Capital (U.S.A.), you may also contact Andrew Abbott at (403) 607-2185,  aabbott@tristonecapital.com or David Vankka at (403) 612-4364, dvankka@tristonecapital.com to place trades.  For Tristone Capital Co., you may also contact Brian Racanelli at bracanelli@tristonecapital.com, (201) 919-8089, or Michael Chewning at mchewning@tristonecapital.com, (201) 919-8089 to place trades.  If you cannot access us through either of those means, you should contact our clearing firm, National Bank --Correspondent Network, at (416) 542-2255 or Pershing, LLC at (201) 413-4672 and www.pershing.com for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions for your customers.

Our Business Continuity Plans - We plan 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 allowing our customers to transact business. In short, our business continuity plans are designed to permit our Firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plans 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, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our affiliate, Tristone Capital Inc. and the clearing firm which they utilize are both located in Canada and have business continuity plans in place should a Signficant Business Disruption occur. As every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, your orders could be delayed during this period. Our clearing firms, National Bank and Pershing, LLC back up our important records in a geographically separate areas. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objectives are to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 4 hours. Your orders and requests for funds and securities could be delayed during this period.

In instances where you invest directly, the entities that you have invested in are responsible for those records they maintain on your behalf. Additionally, when you invest with our assistance, we take steps to assure that you have paper or electronic copies of everything that you have signed and or obligated your self to, which results in your having access to essentially the same records as us, should you be unable to contact us during a an emergency situation. Finally, while most transactions done through us are not time sensitive, every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption. Thus, while each entity with which you have invested desires to restore its own operations and be able to complete existing transactions and accept new transactions and payments within a short period of time, your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions - Significant business disruptions can vary in their scope, such as only our Firm, a single building housing our Firm, the business district where our Firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our Firm or a building housing our Firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 48 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 48 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.tristonecapital.com or our customer emergency numbers, (403) 294-9541 and (303) 952-2800 on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.

For more information - If you have questions about our business continuity planning, you can contact us at (403) 294-9541 or (403) 303-8653.

This plan is subject to modification, an updated summary will be promptly posted on our Web site and customers may alternatively obtain updated summaries by requesting a written copy by mail.

Last Updated: June 2008