Gardnyr Michael Capital, Inc.

Gardnyr Michael Capital, Inc (B.C.P)

Gardnyr Michael Capital (GMC) takes the threat of a significant business disruption very seriously. This notice is being provided to you so that, in the event an internal or external disruption affects our firm, you will know whom to contact. Please note that these procedures apply only to an emergency situation as described below.

GMC anticipates two kinds of business disruptions: internal and external. Internal disruptions affect only our firm's ability to communicate and do business, such as a fire in our building. External disruptions prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external business disruption relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm, Sterne Agee and Leach.

There are various ways through which you, the client, may communicate with us, your brokerage firm. You may contact us through either of our retail locations via US mail or in person at the addresses 2281 Lee Road, Suite 104 - 105, Winter Park, FL 32789; and 500 Boulevard Park East, Mobile, AL 36609. Conversely, you may call our Florida office at the telephone number (407) 629-4600 or you may reach our Alabama location at the telephone number (251) 342-6384. You may also call us toll-free using (800) 231-0082. You may contact us by facsimile using (407) 629-2101 or (251) 344-7526. Last, you may contact us via the Internet, at our Web address: GardnyrMichaelCapital.com.

Should we experience a significant business disruption at either of our locations, we ask that you contact us using any of the available means noted above. If our Internet service is available, we will post on our Web site specific instructions on how to contact us and the method by which you may place orders/requests. If both of our locations have become inoperable and you have exhausted all of the methods suggested in paragraph 2, please contact our clearing firm at the telephone numbers (800) 778-6257, (888) 678-3763 or (800) 264-4863. Alternatively, you may check our clearing firm's Web site at www.salclearing.com.

GMC's primary concern is for the safety of our employees. Once we have secured a safe location from which our firm may operate, our goal is to resume communications and the processing of client orders within 4 hours of a disruption. A resumption time frame of 4 hours is possible due to the nature of our relationship with our clearing firm and its multitude of locations and order-entry data circuits. A more serious disruption may warrant a longer business resumption time-frame.

All client transactions are sent to our clearing firm, which executes our orders, compares them, allocates them, clears and settles them. Our clearing firm also maintains our customers accounts, copies of all new account paperwork, can grant customers access to their accounts, and delivers funds and securities. Alternative means exist for the recovery of client records and for the resumption of GMC's business.

This Plan is subject to annual review and may be modified. The most recent copy of our Plan may always be found on our Web site: GardnyrMichaelCapital.com. Conversely, you may request a copy at any time via U.S. mail.

Please direct any questions regarding this notice to Angela Fiorentino at the telephone number (800) 231-0082.