BUSINESS CONTINUITY PLAN NOTICE

Investment Design Management LLC (“IDM”) maintains a business continuity plan designed to minimize significant business disruptions and allow for the restoration of critical resources should access to our offices or systems become unavailable. This plan identifies mission-critical processes and provides for their recovery in the event of various types of business interruptions. This plan is continually evaluated and amended as necessary to ensure that the impact of any business interruption is minimized.

IDM has chosen to provide this Summary Disclosure via the firm’s website found at www.investmentdesignmangement.com, or by e-mail upon either a verbal or written request. It is important to note that IDM’ BCP is subject to modification. Upon any such modification, an updated Summary Disclosure will be posted immediately on the firm’s website. Customers may also receive such updates by mail upon written or verbal request.

IDM realizes the importance of providing uninterrupted business regardless of adverse conditions and has enacted procedures to ensure the services and support systems necessary to meet all existing obligations. We believe that our plan adequately identifies and eliminates business continuity risk associated with various types of significant business disruptions (whether firm only, single building, business district- wide, citywide, or region-wide).

Provisions for financial and operational assessment are in place to insure the quick recovery and resumption of operations, as well as protection of all of the firm’s books and records. Designated emergency contact persons for IDM oversee IDM’s emergency backup systems. Included in these are systems for electronically backing up and storing data. Also, a cloud based off-site location is utilized for storage of electronic copies of books and records. As to IDM employees, contact lists for all IDM employees are kept current. IDM has various methods for contacting our employees and all employee swill be able to meet at our designated backup location.

In the event of a significant business disruption, IDM customers are assured that they will have prompt access to their funds and securities. Our firm is an advisory firm and does not perform any type of clearing function for itself or others. We do not hold customer funds or securities. All transactions are cleared on a fully disclosed basis through our custodians. IDM is in possession of custodians’ BCP and has communicated with them regarding any necessary BCP issues.

In the event of a significant business disruption, IDM will move our operations to our designated backup/recovery site. Necessary business tools, such as computers, phones, etc. may be kept at our backup site and will be tested annually or are otherwise not machine specific and alternative equipment is available. Details pertaining to the location of our backup facility, any existing arrangements, any individuals with whom those arrangements have been made and other details cannot be disclosed for security reasons.

In the event of a significant business disruptions, our website www.idmfinancialplanning.com will contain alternate telephone numbers for both IDM and our custodian in order to provide clients access to their account.

This BCP is subject to change without notice. If material changes are made to IDM’s BCP, an updated disclosure will be posted on IDM’s website.