Guggenheim Real Estate: Business Continuity Planning

Guggenheim Real Estate LLC (“GRE” or the “Firm”) is devoted to ensuring that mission critical business activities can always be performed. The Firm’s goal is to respond to a Significant Business Disruption (“SBD”) by safeguarding employees’ lives and Firm property as well as 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.

To fulfill this goal, GRE has developed a plan for Business Continuity Management (the “Plan”) that includes provisions for disaster recovery, business recovery, business resumption, contingency planning, and crisis management, with the required information and resources available to enable mission critical processes to be performed during a disaster. In the event that we determine we are unable to continue our business, we assure customers prompt access to any funds due to them.

The Plan details the efforts we will make to address any SBD, whether it is internal or external. This document summarizes the Plan and the actions we will take to overcome any SBD quickly and efficiently. Customers may obtain a copy of the Plan by sending a written request to GRE.

SBD Crisis Response Team Members are Mike Miles, Michael Della Fera, and Patricia Richardson, all of whom are individually authorized to declare an SBD. In the event of an SBD, these individuals will cause all of our employees to be immediately notified.

GRE shall review the Plan annually and modify, if necessary, to reflect any changes in our operations, structure, business or location. In addition, GRE will update the Plan whenever there are material changes to our operations, structure, business or location of our company or our vendors that operate or administer our mission critical applications. If the Plan is modified, an updated summary will be promptly posted on our website, located at http://www.guggenheimrealestate.com.

Once a SBD occurs, the Crisis Response Team, or others designated by the Team, will set the Plan in action. First, the safety of all employees will be considered. Second, data will be gathered on the SBD and the effects on systems and other resources. Finally, a decision will be made on how to respond.

GRE “mission critical systems” are those that ensure prompt and accurate processing of investment transactions, the maintenance of customer accounts, access to customer accounts, and the safekeeping of fund assets. The resources necessary to perform these mission critical functions as well as the disaster recovery approach and recovery times are as follows:

Mission Critical Resource	Detailed Requirements	Disaster Recovery Approach	Recovery Time
Phones	Corporate and cellular phones.	Use phones from home and cellular.	Incoming corporate calls would not be received but alternatives would be immediately accessible.
E-mail	Corporate e-mail.	Application hosted in Chicago and accessible remotely via wide area network. Also email via BlackBerry can be used.	Immediately accessible through BlackBerry and wide area network.
Network files	Files stored on network.	File server hosted in Chicago and accessible remotely via wide area network.	Immediately accessible through wide area network.
Network applications	Applications available on network	Applications available on file server hosted in Chicago and accessible remotely via wide area network.	Immediately accessible through wide area network.
Contact Information	Stored in Outlook, GRE’s contact management database and Blackberry.	Outlook and GRE’s contact management database are on file server hosted in Chicago and accessible remotely via wide area network. Also accessible via Blackberry.	Immediately accessible through Blackberry and wide area network.
Hardcopy Documents	Legal documents, subscription documents, property records and related contracts, financial and tax reporting.	All Documents are stored in at least one other location. Firm’s outside legal counsel – copies of all legal documents; Firm’s recordkeeper – client subscription documents and cash instructions; Documents pertaining to property records and fund books are in custody of asset managers.	Dependent upon type of document.

Service Providers
GRE relies on the services provided by a number of firms for its business process requirements. In the event the Plan is put into action, Michael Della Fera is responsible for notifying certain key service providers as detailed in the Plan. The remainder of the service providers will only be notified as deemed necessary.

IT Backup and Storage
As part of normal operations, all systems and data stored on the Firm’s network are being backed up on tapes every evening. These tapes are stored on 20-day rotations and a copy is stored off site every week in a storage facility managed by an outside storage company.

Business Continuity
GRE is committed to responding to an SBD efficiently and effectively in order to resume normal business as quickly as possible. We will do everything in our power to communicate with our customers and mission critical partners the status of our operations as frequently as we deem necessary.

Business Continuity Planning

Disaster Recovery and Business Continuity Plan Summary