Santander Securities, LLC BUSINESS CONTINUITY PLAN PROGRAM

April, 2016

Business Continuity Plan (BCP)

Table of Contents

I. Introduction 4

II. Emergency Contact Person 4

III. Firm Policy 5

A. Significant Business Disruptions (SBD) 5

B. Disaster Recovery Contingency Plan 5

C. Approval and Execution Authority 5

D. Plan Location and Access 6

E. Support, Resources and Back-up 6

IV. Business Description 7

V. Office Locations 7

VI. Alternative Physical Location(s) of Employees 8

VII. Customers’ access to Funds and Securities 9

VIII. Data Back-up and Recovery (Hard Copy and Electronic) 10

IX. Financial and Operational Assessments 11

A. Operational Risk 11

B. Financial and Credit Risk 11

X. Mission Critical Systems 11

A. Our Firm’s Mission Critical Systems 13

B. Mission Critical Systems Provided by our Clearing Firm 14

XI. Alternate Communications between the Firm and Customers,

Employees and Regulators

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A. Customers 14

B. Employees 14

C. Regulators 15

XII. Critical Business Constituents, Banks and Counter-parties 16

A. Business Constituents 16

B. Banks 16

C. Counter-parties 17

Table of Contents

XIII. Regulatory Reporting 17

XIV. Disclosure of Business Continuity Plan 17

XV. Updates and Annual Review 18

XVI. Senior Manager Approval 18

Exhibits 19

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Business Continuity Plan (BCP)

I. Introduction

FINRA Rule 4370 requires broker-dealers to create and maintain a written business

continuity plan identifying procedures relating to an emergency or significant business

disruption. Such procedures must be reasonably designed to enable the broker-dealer to

meet its existing obligations to customers. In addition, such procedures must address the

member's existing relationships with other broker-dealers and counter-parties.

The Business Continuity Plan (“BCP”) outlined in this document describes the steps

Santander Securities LLC (“SSLLC” or the “Firm”) will take to recover its critical

business functions and systems in the event of a significant business disruption (“SBD”)

as well as provide procedures for response and recovery in the event of a SBD. The BCP

covers its operations in the Northeast Region (“NRD”), Puerto Rico, and Miami.

SSLLC’s BCP plan includes the following elements:

Data back-up and recovery (hard copy and electronic);

All Mission critical systems;

Financial and operational assessments;

Alternate communication between customers and SSLLC;

Alternate communication between SSLLC and its employees;

Alternate physical locations of employees;

Critical business constituent, bank, and counter-party impact;

Regulatory reporting;

Communications with regulators; and

How SSLLC will assure customers’ prompt access to their funds and securities in

the event that SSLLC determines that it is unable to continue its business.

II. Emergency Contact Persons

SSLLC’s Executive Representative, Fernando Batlle, President and CEO and Mark

Pinocci, Director of Risk, are designated as SSLLC’s emergency contact persons. There

contact information is noted below:

Fernando Batlle, 75 State Street, 617-346-7227 (office), 617-615-5671 (cellular)

fbatlle@santandersecurities.com.

Mark Pinocci, 2 Morrissey Blvd., 617-474-5425 (office), 617-480-2588 (cellular)

mpinocci@santandersecurities.com.

SSLLC will provide FINRA with the contact information via the CRD system for the

emergency contact persons named above. The Licensing & Registration Department will

promptly notify FINRA via CRD of changes to the information noted above (no later than 30

days following the change). Annually, the Licensing & Registration Department will review

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the Firm’s emergency contact information in CRD to verify the accuracy, and if necessary,

update this information within 17 business days after the end of each calendar year.

III. Firm Policy

SSLLC’s policy is to respond to a 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 SSLLC determines it is unable to continue its business it will

assure customers prompt access to their funds and securities.

A. Significant Business Disruptions (SBDs)

SSLLC’s plan anticipates two kinds of SBDs, internal and external:

Internal SBDs affect only our firm’s ability to communicate and/or do

business, such as a fire in one of our buildings.

External SBDs prevent the operation of the securities markets or a number of

firms, such as a terrorist attack, a city flood, snow storm or hurricane, or a

wide-scale, regional disruption, power outage, etc. Our response to an

external SBD relies more heavily on other organizations and systems,

especially on the capabilities of our clearing firm, Pershing LLC (“Pershing”).

B. Disaster Recovery Contingency Plan

SSLLC will coordinate with Santander Puerto Rico (“SPR”), Banco Santander

International (“BSI”), and Santander Bank N.A. (“SBNA”), so that SSLLC’

activities in Puerto Rico, Miami and the NRD are supported in their respective

Disaster Recovery Contingency Plans (“DRCP”), to suffice those areas where a

SBD is beyond the scope of the Firm’s BCP.

C. Approval and Execution Authority

The Director of Risk has been granted the authority to approve and for

conducting the required annual review. The Chief Operating Officer (“COO”)

has the authority to execute this BCP.

In the event of an SBD, the Director of Risk will contact SSLLC’s BCP

Response Team by either conference call, email, or whatever means are still

available to discuss the SBD. The BCP Response Team will meet to discuss the

SBD and make a decision to initiate the BCP, if necessary.

The BCP Response Team will be made up of the following individuals:

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President & CEO

Director of Risk

Director of Product

Chief Compliance Officer

Chief Operating Officer

Managing Director Puerto Rico

Director of Sales NRD

Branch Manager, Miami

Chief Financial Officer

D. Plan Location and Access

SSLLC will maintain copies of its BCP plan and the annual reviews, and the

changes that have been made to it for inspection. An electronic copy of our plan is

located on our local servers (BSPR and SSLLC) and in external repository

company, TDATA. In addition, SSLLC will post its BCP on its intranet site so

that is available to all employees and registered persons.

E. Support, resources and back-up

SSLLC’s Puerto Rico Division activities are supported from its office in San Juan,

Puerto Rico, where Operations, Compliance, Finance, Retail Sales and other

functions are located. In case of a SBD in this location, immediate support will be

provided from the Firm’s offices in Dorchester, MA, while we activate our

alternate location to resume contingency support services.

SSLLC’s NRD business is supported from its offices in Dorchester, MA, where

Operations, Compliance, Retail Sales Support and other functions are located. In

case of a SBD in this location, immediate support will be provided from the

Firm’s office in San Juan, Puerto Rico, while we activate our alternate location to

resume contingency support services.

SSLLC’s Miami business is supported from its Miami office. In the case of an

SBD in this location, immediate support will be provided from the Firm’s office in

San Juan, Puerto Rico, while we active the alternate location to resume

contingency support services.

Pershing is SSLLC’s clearing firm and provider of NetX360, a mission critical

system. The Pershing contract states that they will maintain a business continuity

plan and have the capacity to execute that plan; represents that it will advise

SSLLC of any material changes to its plan that might affect its ability to support

SSLLC’s business. In the event Pershing executes its plan, it represents that it will

notify SSLLC of such execution and provides SSLLC equal access to services as

its other customers. If SSLLC reasonably determines that Pershing has not or

cannot put its plan in place quickly enough to meet SSLLC’s needs, or is otherwise

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unable to provide access to such services, Pershing represents that it will assist us

in seeking services from an alternative source.

Pershing represents that it backs up SSLLC’s records at a remote site, that it

operates a back-up operating facility in a geographically separate area with the

capability to conduct the same volume of business as its primary site, and has also

confirmed the effectiveness of its back-up arrangements to recover from a wide

scale disruption by testing annually and it has confirmed that it tests its backup

arrangements in four (4) hours.

At minimum annually, SSLLC’s COO shall review Pershing’s BCP to determine

if there are any gaps associated with it. If gaps are identified the COO will

immediately raise them to senior management (CEO and Director of Risk) so that

appropriate action can be taken. In addition, the COO will review Pershing’s

semi-annual Disaster Recovery Testing Attestation (“Attestations”). Refer to

Exhibit A for Pershing’s BCP.

IV. Business Description

SSLLC is an introducing firm and does not perform any type of clearing function for itself or

others. Specifically, SSLLC is a full service broker-dealer offering securities (e.g., Fixed

income, equities, mutual funds, variable annuities, and advisory products) and insurance

products (e.g., Fixed annuities and life insurance) to retail and institutional clients in the

United States and Puerto Rico. In addition, SSLLC also provides limited investment banking

services through its participation in the underwriting of Puerto Rico municipal bonds and

investment banking advisory services. SSLLC’s primary business is to provide customers

with investment and insurance solutions that are consistent with their risk profile and

investment goals/needs. Furthermore, SSLLC does not hold customer funds or securities.

As noted above, SSLLC’s clearing firm is Pershing. Pershing’s contact information is noted in

the table below:

Pershing, LLC

(Main Contact Information)

PO BOX 2065

Jersey City, NJ 07303

www.pershing.com

T: (201) 413-3635

F: (201) 413-5368

Alternate T: (213) 624-6100,

Ext. 500 (recorded instructions)

Pershing Main Contact Person Kenneth Vinci, Director

kvinci@pershing.com

T: (201) 413-4144

Pershing Alternate Contact

Person

Jennifer Elvin

Evangeliou, Account

Manager

T: (201) 761-5051

V. Office Locations

A. Office Location #1 (OSJ location) is located at 75 State Street, Boston, MA 02109.

The main office number is (617) 346-7277 Employees may travel to this office by

means of car, train, subway, bus, or foot. SSLLC’s CEO and Chief Legal Officer are

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housed at this location.

B. Office Location #2 (OSJ location) is 2 Morrissey Boulevard, Dorchester, MA,

02125. The main telephone number is (617) 379-4226. Employees may travel to that

office by means of car, train, subway, bus, or foot. SSLLC’s senior management team

is housed at this location, which includes the Chief Compliance Officer, Chief

Operating Officer, Head of Product, and Director of Risk. Additionally, the following

activities are performed at this location: 1) review and approval of securities and

insurance trades; 2) compliance activities (e.g., review and approval of

advertising/sales material, email surveillance, trade surveillance, & licensing &

registration); 3) operational activities (e.g., process ACATs, money movements, etc.);

4) retail sales support and 5) commission and incentives functions.

C. Office Location # 3 (OSJ location) is 207 Ponce de Leon Ave, 4th

Floor, San Juan,

PR 00917-1818. The main number is (787) 759-5330. Employees may travel to this

office by means of car, train, bus, or foot. SSLLC engages in these activities at this

location: 1) open new client accounts: 2) execute client orders; 3) investment banking;

4) operational activities (e.g., cashiering, wire requests, ACATs, etc.); 5) supervisory

activities; 5) trading/capital markets; 6) finance and accounting functions; and 7)

compliance related functions.

D. Office Location # 5 (OSJ location) is 1401 Brickell Ave., Suite 100, Miami, FL

33131. The main telephone number is 305-539-5641. SSLLC engages in these

activities at this location: 1) open new client accounts; 2) execute client orders; and 3)

operational activities.

E. Office Locations #6 is the registered branch offices in New York, New Jersey,

Pennsylvania, Connecticut, Rhode Island, Massachusetts, and New Hampshire.

SSLLC engages in the sale of securities or insurance products in these locations by a

team of registered persons. Refer to Exhibit B for the list of SSLLC’s branch office

locations.

VI. Alternative Physical Location(s) of Employees

Establishment of alternate sites is part of the recovery efforts to mitigate

interruptions due to events that prevent access to employees to regular workings

sites. In the event of an SBD in Puerto Rico, location #2 (Dorchester) will promptly

support the continuity of the business. Our Puerto Rico staff will be relocated from

the affected offices to the nearest of our unaffected office locations or to Santander

Puerto Rico recovery locations. Santander Puerto Rico has the following alternate

recovery sites for relocating its personnel in case of need:

ATENTO Recovery Site, Caguax Ind. Park, Caguas, Puerto Rico, 00925

Datacenter Training Rooms, Arterial Hostos, Hato Rey, Puerto Rico

00917

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SSLLC’s Main Building Hato Rey Conference Room, 4th

Floor, Hato Rey,

Puerto Rico 00917

Due to business infrastructure needs, the following identified applications / services

will be recovered if needed in the following designated alternate sites:

a. Bloomberg

- Personnel from Santander Main Building in Hato Rey using this service

will be recovered in Arterial Hostos, Hato Rey, Puerto Rico.

- Bloomberg terminals are also located in the Miami, FL and Dorchester, MA

offices and provide additional back-up capabilities.

b. Fedline Services

- Personnel from Back Office in Santander Main Building in Hato Rey using

this service will be recovered at the Datacenter, Arterial Hostos Building in

Hato Rey, Puerto Rico.

- Personnel from Operations - Specialized Services in the Datacenter,

Arterial Hostos Building in Hato Rey, Puerto Rico using this service will be

recovered at Santander Main Building in Hato Rey.

In the event of an SBD in Dorchester, locations #s 3 & 4 in Puerto Rico will

promptly support the continuity of the business. SSLLC’s Boston staff will be

relocated from the affected offices to SBNA offices at 75, State Street, Boston

(MA) if available, or to SBNA’s Disaster Recovery Site in 1 Santander Way, East

Providence, Rhode Island.

In the case of an SBD affecting a number of registered branches, SSLLC will

follow SBNA’s BCP and simultaneously relocate its registered personnel to the

nearest available registered branch.

VII. Customers’ Access to Funds and Securities

SSLLC does not hold customers’ funds or securities. Customer funds and securities are

held with our clearing firm, Pershing or the insurance carriers SSLLC has entered into a

selling agreement to sell their products.

In the event of an internal or external SBD, SSLLC will have the ability to contact

customers through multiple avenues. Similarly, customers will be able to access their

funds or securities through multiple sources. First, if phone service is available, SSLLC’s

registered persons will be able to respond to customer questions, inquiries, and facilitate

investments or instructions on behalf of the customer by processing the transaction via

the NetX360 platform or contacting Pershing directly on behalf of the customer. Second,

if web access is available, SSLLC will contact its clients by posting a message on its

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website with instructions on how to access funds, and/or effectuate transactions. Third,

clients will have direct access to the insurance carriers to conduct business of necessary

via the insurance carrier’s customer service number or through their respective web sites.

Refer to Exhibit C for list of insurance carriers.

If SIPC determines that we are unable to meet our obligations to our customers or if our

liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC

may seek to appoint a trustee to disburse our assets to customers. SSLLC will assist

SIPC and the trustee by providing its books and records identifying customer accounts

subject to SIPC regulation.

VIII. Data Back-Up and Recovery (Hard Copy and Electronic)

SSLLC maintains its books and records in both hard copy and electronic format.

Hard Copy Records

For PR activities, hard copy books and records are maintained at Location #1 at 207

Ponce de Leon Ave, San Juan, PR 00917. Rafael Colon Ascar, Managing Director, at

(787) 200-1720 is responsible for the maintenance of the Firm’s business records. In

addition, operations finance and compliance records are also maintained at this

location. Ralph Roman, Director of Operations (787)759-5375, Ivan Castaner,

Compliance Manager, at (787) 281-3527 and Ana del Pilar Rivera, Controller, at (787)

281-3503 are responsible for the maintenance of these records.

For NRD activities, hard copy books and records are maintained at 2 Morrissey

Boulevard, Dorchester, MA, 02125. Craig Maroney, Operations Manager, at (617) 474-

5707 is responsible for the maintenance of these records.

For Miami activities, hard copy books and records are maintained at 1401 Brickell Ave,

Suite 100, Miami, FL. Jaime Annexy, Branch Manager, at (305) 539-5641 is

responsible for the maintenance of these records.

In the event of an internal or external SBD that causes the loss of our paper records,

SSLLC will physically recover these records from its back-up site. If SSLLC’s primary

site is inoperable, SSLLC will continue operations from its back-up site or an alternate

location. For the loss of electronic records, SSLLC will either physically recover the

storage media or electronically recover data from its back-up site, or, if its primary site

is inoperable, continue operations from our back-up site or an alternate location.

Electronic Records

SSLLC’s primary customer records are maintained electronically in the Pershing’s

NetX360 system (segregated by customer). These records include: new account form,

customer identification documentation, margin agreements, options agreements,

compliance disclosure forms, copies of checks, correspondence, letters of

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authorizations. As noted in in the Pershing BCP, these records are backed daily by

them.

The Firm’s financial records are maintained electronically on these systems: 1)

ALTAIR (general ledger system); 2) People Soft (Accounts Payable & Fixed Asset

systems); 3) TUTELA (Data Warehouse). These systems enable SSLLC’s to perform

its net capital calculations, FOCUS reporting, and financial statements. SSLLC

maintains copies of the reports generated. These systems are maintained by SPR and

backed up daily to tape. In the event of an SBD, SSLLC will coordinate with SPR to

ensure access to these systems and the Firm’s financial records.

The Firm backs up its electronic records daily by local backup application software.

Locally hosted applications are fully backed up on tapes which are delivered to a third-

party off-site location (for NRD - Iron Mountain, 203 Moonachie Road Moonachie NJ

07074, phone number (201) 807-0100), and for Puerto Rico - International Safe

Deposit, Ave. Roosevelt #1344, Pueblo Viejo, San Juan Puerto Rico).

IX. Financial and Operational Assessments

A. Operational Risk

In the event of an SBD, SSLLC will immediately identify what means will permit it to

communicate with its customers, employees, critical business constituents, critical banks,

critical counter-parties, and regulators. Although the effects of an SBD will determine

the means of alternative communication, the communications options SSLLC will

employ will include its web site, telephone voice mail, secure e-mail, etc. In addition,

SSLLC will retrieve its key activity records as described in the section above, Data

Back-Up and Recovery (Hard Copy and Electronic).

B. Financial and Credit Risk

In the event of an SBD, SSLLC will review its financial health to evaluate its ability to

continue to fund day-to-day operations and remain in capital compliance. SSLLC will

contact Pershing, Santander Holdings USA, Inc., SPR, SBNA, BSI, and clients to

apprise them of our financial status by either email, telephone, posting a notice on the

SSLLC website or by mail. If SSLLC determines that it may be unable to meet its

obligations to those counter-parties or otherwise continue to fund our operations, it will

request additional financing from other credit sources to fulfill its obligations to its

customers and clients. If we cannot remedy a capital deficiency, we will file appropriate

notices with FINRA and the SEC and immediately take appropriate steps

X. Mission Critical Systems

SSLLC’s “mission critical systems” are those that ensure prompt and accurate

processing of securities transactions, including order taking, entry, execution,

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comparison, allocation, clearance and settlement of securities transactions, the

maintenance of customer accounts, access to customer accounts, and the delivery of

funds and securities. Specifically, these systems include:

o NetX360; System that maintains SSLLC customer account records, positions,

account statements/confirms. In addition, the system is used by SSLLC to place

mutual fund and equity orders for customers and execute customer side fixed

income orders;

o TMC (web-based): Trading system that allows SSLLC’s Trading Desk to

execute street side fixed income trades; and

o Bloomberg: Provides SSLLC’s Trading Desk with access to market prices for

fixed income trades.

SSLLC’s primary responsibility is establishing and maintaining business relationships

with our customers and has sole responsibility for the mission critical functions of order

taking and entry of such orders in the Pershing Platform. Pershing provides, through its

contract, the execution, comparison, allocation, clearance and settlement of securities

transactions, the maintenance of customer accounts, management of confirmations and

account statements, access to customer accounts, and the delivery of funds and

securities.

Pershing provides that will maintain a business continuity plan and the capacity to

execute that plan. Pershing represents that it will advise SSLLC of any material changes

to its plan that might affect its ability to maintain SSLLC’s business and has presented

SSLLC with an executive summary of its plan. In the event Pershing executes its plan, it

represents that it will notify SSLLC of such execution and provides SSLLC equal access

to services as it does to other customers. If SSLLC reasonably determines that Pershing

has not or cannot put its plan in place quickly enough to meet SSLLC’s needs, or is

otherwise unable to provide access to such services, Pershing represents that it will assist

us in seeking services from an alternative source.

Pershing represents that it backs up SSLLC’s records at a remote site. Pershing

represents that it operates a back-up operating facility in a geographically separate area

with the capability to conduct the same volume of business as its primary site. Pershing

has also confirmed the effectiveness of its back-up arrangements to recover from a wide

scale disruption by testing. Testing is a formal full-cycle process that encompasses

scheduled quarterly tests, ad-hoc testing and external exercises that address business,

technology, audit and compliance requirements

Recovery-time objectives provide concrete goals to plan for and test against. They are

not, however, hard and fast deadlines that must be met in every emergency situation, and

various external factors surrounding a disruption, such as time of day, scope of

disruption and status of critical infrastructure—particularly telecommunications—can

affect actual recovery times. Recovery refers to the restoration of clearing and settlement

activities after a wide-scale disruption; resumption refers to the capacity to accept and

process new transactions and payments after a wide-scale disruption. If an incident

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causes the closing of the primary data center, Pershing will declare a disaster recovery

event and activate its disaster recovery plan. This may result in an outage up to four

hours while Pershing’s mainframe processing is transferred to the alternate data center.

Annually, Operations will review Pershing’s capabilities to perform the mission critical

functions the clearing firm has contracted to perform for SSLLC. Documentation of this

review will be maintained by the COO and be available for review by Risk and/or

Compliance.

A. Our Firm’s Mission Critical Systems

1. Order Taking

SSLLC receives orders from customers through registered representatives or

electronically through the website of Net Exchange Client. During an SBD,

either internal or external, SSLLC will continue to take orders through any of

these methods that are available and reliable with the support of the different

locations, and in addition, as communications permit, SSLLC will inform its

customers when communications become available to tell them what

alternatives they have to send their orders to us. Customers will be informed of

alternatives by phone and internet.

2. Order Entry

SSLLC’ registered representatives enter orders through Pershing’s NetX360

platform (equity and mutual fund orders) and subscribe (annuity orders)

systems or through SSLLC’s trading desk (fixed income only).

In the event of an internal or external SBD, SSLLC will enter and send records to

Pershing from the support locations or, if necessary, by the fastest alternative

means available, which include fax, email, or telephone. In the event of an

external SBD, we will maintain the order in electronic or paper format, and

deliver the order to Pershing by the fastest means available when it resumes

operations. In addition, during an internal SBD, SSLLC may need to refer its

customers directly to Pershing to effect transactions.

3. Order Execution

SSLLC clears through Pershing under a fully disclosed basis. Customer’s mutual

fund and equity orders are executed by Pershing. Customer’s fixed income

trades are executed by SSLLC’s trading desk located in Puerto Rico. In the event

the trading desk is unable to execute fixed income trades due to an SBD, the

Director of Trading will contact Pershing’s trading desks to execute customer’s

fixed income trades.

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4. Other Services Currently Provided to Customers

In addition to those services listed in this section, SSLLC also processes checks,

accept deposits, and process fund transfers and disbursements. In the event of an

internal SBD, SSLLC can process asset movements in the registered branches.

Alternately, SSLLC can instruct customers to process these transactions directly

with the support of the OSJ offices in Puerto Rico or Dorchester, MA.

In the event of an external SBD, customers can process these transactions by

contacting their financial consultant, who again will be supported by the Main

Offices, or directly through Pershing.

B. Mission Critical Systems Provided by Our Clearing Firm

SSLLC relies, by contract, on Pershing to provide order execution, order

comparison, order allocation, customer account maintenance, delivery of funds

and securities, and access to customer accounts.

The mission critical system which provides SSLLC with the functions noted

above is NetX360.

Pershing has represented to SSLLC, through its BCP, that it can expect service

restoration within 4 Hours regarding NetX360.

XI. Alternate Communications Between the Firm and Customers,

Employees, and Regulators

A. Customers

SSLLC now communicates with its customers via in-person meetings at one of

SSLLC’s registered branch office locations, the telephone, e-mail, SSLLC’s Web

site, fax, and U. S. mail. In the event of an SBD, SSLLC will assess which means of

communication are still available and use the means closest in speed and form

(written or oral) to the means that we have used in the past to communicate with the

other party. For example, if we have communicated with a party by e-mail but the

Internet is unavailable, we will call them on the telephone and follow up where a

record is needed with paper copy in the U. S. mail.

B. Employees

SSLLC now communicates with its employees using the telephone, e-mail, and in

person. In the event of an SBD, SSLLC will access which means of communication

are still available, and use the means closest in speed and form (written or oral) to the

means that we have used in the past to communicate with the other party. We will

also employ a call tree so that senior management can reach all employees quickly

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during an SBD. The call tree includes all staff home and office phone numbers.

Refer to Exhibit D for SSLLC’s Call Tree.

At least once a year, SSLLC management will perform a Call Tree test to ensure the

call tree process is adequate. These tests will be documented and available for review

upon request by Compliance or Internal Audit area.

The person to invoke use of the call tree is: Fernando Batlle.

Caller Call Recipients

Fernando Batlle Mark Pinocci

Mark Pinocci Rafael Colon Ascar, Luis Roig, Maura Almy, Larry Carter,

Jeff Weiner, Xiomara Corral, Jaime Annexy, and Northeast

National Sales Director

Rafael Colon Ascar John Watson, Gerardo Portela, Rebecca Feliciano, Eduardo

Cases, and Puerto Rico Financial Consultants

Luis Roig Finance & MIS

Lawrence Carter Scott Solod, John Clark, Todd McCoy

Northeast National Sales

Director

Santander Investments NRD Regional Sales Managers,

Santander Investments NRD support staff

Jeff Weiner Product Department

Maura Almy Craig Maroney, Ralph Roman, Brendan Carroll, and Chris

Cheney

John Watson Trading Department

Ralph Román Operations Department Puerto Rico

Rebecca Feliciano Sales Assistants

Scott Solod Ivan Castaner, Mary Diaz, Sarah Currier, and Jack Butler

Todd McCoy AML Department

Jack Butler Principal Review Unit

Sarah Currier Branch Inspection Unit

Gerardo Portela Laura Franceschi

Jaime Annexy Miami office personnel

Craig Maroney Northeast Operations

Brendan Carroll IT Department

NRD Regional Sales Managers NRD Financial Consultants

C. Regulators

SSLLC is registered with the United States Securities & Exchange Commission

(“SEC”), Financial Industry Regulatory Authority (“FINRA”), Municipal Securities

Regulatory Board (“MSRB”), the Office of the Commissioner of Financial

Institutions of Puerto Rico (“OCFI”) and various states securities regulators. SSLLC

will communicate with the aforementioned regulators, if required, using the

telephone, email, fax, U.S. mail, or in person. In the event of an SBD, we will assess

which means of communication are still available to us, and use the means closest in

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speed and form (written or oral) to the means that we have used in the past to

communicate with the other party. At a minimum, SSLLC will contact these

regulators in the event of an SBD (there contact information is noted in Section XIII

below):

SEC

FINRA

MSRB

OCFI

XII. Critical Business Constituents, Banks, and Counter-Parties

A. Business constituents

SSLLC will contact its critical business constituents (businesses with which we have

an ongoing commercial relationship in support of our operating activities, such as

vendors providing us critical services), and determined the extent to which SSLLC

can continue its business relationship with them in light of the internal or external

SBD. SSLLC will quickly establish alternative arrangements if a business

constituent can no longer provide the needed goods or services when SSLLC needs

them because of a SBD to them or SSLLC or SSLLC has entered into a

supplemental contract with certain critical business constituents to provide such

services. SSLLC’s critical business constituents include:

Constituents’ Name Address Phone Number

Pershing, LLC- Main Office PO BOX 2065

Jersey City, NJ 07303

(201) 413-2000

(201) 413-3635

SSLLC does not anticipate Pershing not being able to provide us with their critical

services as they indicate in their BCP that they can be operational within 4 hours of a

SBD.

B. Banks

SSLLC will contact its banks/lenders to determine if they can continue to provide the

financing that we may need in light of the internal or external SBD. The bank

maintaining SSLLC’s operation account is Banco Santander Puerto Rico, PO Box

362589, San Juan PR 00936-2589, (787) 777-4100. If Banco Santander Puerto Rico

is unable to provide the financing SSLLC will seek alternative financing

immediately from other banks.

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C. Counter-Parties

SSLLC will contact its critical counter-parties, such as other broker-dealers or

institutional customers, to determine if it will be able to carry out its transactions

with them in light of the internal or external SBD. Where the transactions cannot

be completed, SSLLC will work with Pershing or contact those counter-parties

directly to make alternative arrangements to complete those transactions as soon as

possible. Refer to Exhibit E for list of SSLLC’s approved counterparties.

XIII. Regulatory Reporting

SSLLC is registered with these regulators: SEC, FINRA, MSRB, OCFI and various state

securities divisions. Currently, SSLLC files reports with the aforementioned regulators

via U.S. mail, messenger, or electronically using fax, e-mail, or the internet (FINRA’s

CRD system). In the event of an SBD, SSLLC will check with the regulators to

determine which means of filing are still available, and use the means closest in speed

and form (written or oral) to SSLLC’s previous filing method. In the event that SSLLC

cannot contact its regulators, SSLLC will continue to file required reports using the

communication means that are available.

Name Address Contact Number

OCFI Centro Europa Building,

6th Floor

Santurce, PR 00907

Tel: (787) 723-3131

Fax: (787) 724-4225

FINRA 20 Broad Street, 21st Floor

New York, NY 10005

Tel: (646) 315-8517

Fax: (646) 483-6350

FINRA 5200 Town Center Circle,

Suite 200

Boca Raton, FL 33486

Tel: (561) 416-0277

Fax: (301) 527-4868

MSRB 1900 Duke Street Suite 600

Alexandria, VA 22314

Tel: (703) 797-6600

Fax: (703) 797-6700

SEC 801 Brickell Avenue,

Suite 1800

Miami, FL 33131

Tel: (305) 982-6300

Refer to Exhibit F for state securities divisions’ contact information.

XIV. Disclosure of Business Continuity Plan

SSLLC discloses to its customers how its business continuity plan addresses the

possibility of an SBD and how it plans to respond to such events. SSLLC

provides this disclosure to its customer at account opening (included as part of

the New Account Form). SSLLC also posts the disclosure statement on its Web

site and will mail it to customers upon request.

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XV. Updates and Annual Review

SSLLC firm will update its BCP whenever there is a material change to its operations,

structure, business or locations. In addition, SSLLC will review this BCP annually to

modify it for any changes in our operations, structure, business, or locations.

XVI. Senior Manager Approval

I have approved this BCP as reasonably designed to enable SSLLC to meet its

obligations to its customers in the event of an SBD.

Signed:

Title:

Date

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EXHIBITS

Exhibit A – Pershing’s BCP

Pershing LLC Contingency Planning - Exec Summary January 2016 Final.pdf

Exhibit B – SSLLC Branch Office List

2016-04-11 Branch Roster.xlsx

Exhibit C – List of Insurance Carriers

Insurance Carrier Contact List 2015-04-01.xlsx

Exhibit D – SSLLC’s Call Tree

BCP Call Tree 04-2016 Final.pptx

Exhibit E – List of Counterparties

COUNTERPARTY LIST 2016.xlsx

Exhibit F – Contact Information State Securities Divisions

State Securities Divisions Contact Information.pdf