INTL Trading Business Continuity Plan (BCP) Disclosure Statement

I. Firm Policy
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.

A. Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’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 firms, 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.

II. Emergency Contact Persons
In the event that the firm experiences a SBD, senor management will call for the implementation of our BCP. During times of a SBD, our firm’s two emergency contact persons are:

Brian Sephton
(O) 407-741-5309
(C) 407-702-5759
bsephton@intltrading.com

Scott Branch
(O) 212-485-3511
(C) 201-406-9901
sbranch@intlassets.com

Our clearing firm is:

Merrill Lynch, Pierce, Fenner & Smith Incorporated (Broadcort Division)
101 Hudson Street
Jersey City, NJ 07302
201-557-4437
anthony_maranzano@ml.com
www.broadcort.com
Contact Person is Anthony Maranzano
(O) 201-557-3852

III. Office Locations
Our Firm has offices located in Location #1, Location #2, Location #3, and Location #4.

A. Office Location #1
Our Location #1 Office is located at
220 E Central Parkway, Suite 2060, Altamonte Springs, FL 32701.
Its main telephone number is +1 (407) 741-5300.

B. Office Location #2
Our Location #2 Office is located at
708 3rd Avenue, NY, NY 10017.
Its main telephone number is +1 (212) 485-3500

C. Office Location #3
Our Location #3 Office is located at
Phoenix House, 18 King William Street, London EC4N 7BP.
Its main telephone number is 011-44 207 220 6060

D. Office Location #4
Our Location #4 Office is located at
1111 Brickell Ave, Suite 1575, Miami, FL 33131.
Its main telephone number is 305-377-0201

IV. Severity of SBDs
Our BCP takes into account various levels of disruption. Because office locations serve as a backup to each other and are located in different regions, we are confident that we can continue operations during an SBD to a specific building, business district, city or region. If one of these types of SBD’s were to affect one of our locations, it is our intent that the unaffected location would immediately assume the functions of the affected one; however, some functionality might take up to 4 hours to be restored. Every in-house and supplier provided system is available in both the New York and Altamonte Springs, FL locations. Some of these systems are available in London and Miami. Of course, we are dependent on some systems from outside providers. In the event of an SBD that affects a business district, city or region, an unaffected office might be unable to utilize the services of some of these outside providers until such time as these providers have restored service. Our mission critical providers all have stated plans for restorations of services within 4 hours. It is necessary to recognize that it is possible for an SBD of sufficient magnitude where these providers would be unable to meet their 4 hours goal. Nevertheless, our contingencies should ensure that we return to operations concurrent with the restorations of operations of the major U.S. Equity and Fixed Income Markets from any wide spread SBD.

Because of our redundancies and security of our systems, we believe that our exposure to an SBD limited to our firm is minimal. If an event was to occur that rendered all US offices inoperable, we would rely on the support of our clearing firm (Broadcort) to help us restore operations, while ensuring that all pending transactions were properly completed.

V. Communications
Our BCP is subject to modification. A link to any updated summary will be posted on our Web Site when modifications occur. Customers may alternatively obtain updated summaries by requesting a written copy by mail by writing to:

INTL Trading
220 E Central Parkway
Suite 2060
Altamonte Springs, Fl 32701
Attn: Compliance Department