BUSINESS CONTINUITY PLAN DISCLOSURE

D.M. Kelly & Company, (D.M. Kelly) a full-service broker dealer, and its affiliate DMKC Advisory Services, LLC, (DMKC) an investment adviser, maintain important disaster recovery and Business Continuity Plans that may be activated in the event of a significant business disruption. The firm realizes the critical nature of being able to continue material operations if an incident occurs that could affect mission-critical business units and systems. This plan is a key component in maintaining emergency procedures and is required by securities industry regulations.

Contacting Us - If after a significant business disruption you cannot contact us at 515-221-1133, you should go to our website at www.dmkc.com. If you cannot access us through either of these means you should contact our clearing firm, First Clearing LLC, 901 East Byrd Street, Richmond, VA 23219, 800-727-0304. You will be given instructions on how to receive prompt access to funds and securities, enter orders and process other trade-related cash and security transfer transactions.

Our Business Continuity Plan - We plan to quickly recover and resume business operations after a significant business disruption and respond by safe-guarding 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 plan is designed to permit the firm to resume operations as quickly as possible given the scope and severity of the business disruption.

We address the following in our Business Continuity Plan: 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 assurance that our customers have prompt access to their funds and securities if we are unable to continue business.

First Clearing, LLC backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors such as time of day and severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within the same business day. Regardless of these efforts, it is important to note that your orders and requests for funds and securities could still be delayed during this period.

D.M. Kelly and DMKC have contractual agreements with First Clearing, LLC to serve as the respective clearing firm. This fully disclosed agreement states the responsibilities of each party. Prior to the agreement becoming effective, First Clearing, LLC is responsible for making all disclosures to D.M. Kelly and DMKC's designated examining authority as required by NYSE Rule 382. Each client of D.M. Kelly and DMKC is notified of the relationship via a disclosure letter. The disclosure letter details the responsibilities that D.M. Kelly (the introducing broker-dealer) or DMKC (the investment adviser) and First Clearing, LLC (the clearing firm) each have to the client. Although client assets are held by First Clearing, LLC, First Clearing LLC does not have responsibility for the financial condition or performance of D.M. Kelly, DMKC or our Financial Consultants.

Varying Disruptions - Significant business disruptions can vary in their scope. For example a disruption could impact only the firm, the building housing our firm, the business district where our firm is located, the city where we are located, or even the whole region. Within each of these areas, the severity of the disruption could also vary from minimal to severe. In a disruption to only our firm or the building housing our firm, we will transfer operations to a local site as needed and expect to recover and resume business within the same business day. 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 the same business day. In either situation, we plan to continue to do business, transferring operations to our clearing firm if necessary. Access our website www.dmkc.com or call our customer emergency number at 515-279-5650 to learn how you can contact us.

For More Information - If you have questions about our Business Continuity Plan contact us at 515-221-1133. Clients should be aware that because the firm's plan contains details of a confidential and proprietary nature, it cannot be distributed to the public. Clients should also note that D.M. Kelly and DMKC's Business Continuity Plan is subject to modification and updated plans will be promptly posted on D.M. Kelly and DMKC's website at www.dmkc.com as permitted by applicable law.

D.M. Kelly & Company

3900 Ingersoll Avenue, Suite 300 • Des Moines, IA 50312

515-221-1133 • 800-998-9773