Business Continuity Disclosure

KeyBanc Capital Markets Inc. (“KBCM”), through KeyCorp's Enterprise Business Resiliency group, maintains comprehensive processes to effectively respond to an incident to achieve and sustain continuous business operations, with limited impact to the business, while being consistent with industry standards and meeting regulatory expectations.

In addition, KBCM, part of Cleveland-based KeyCorp, maintains a Business Continuity Plan (“BCP”) in accordance with NYSE Rule 446 and FINRA Rule 4370 regarding customer communications. The provisions of these rules require KBCM to summarize its plan during significant business disruptions with varying severity for its customers, as follows:

• KeyCorp maintains a primary data center with data replication and recovery systems in a secondary data center which includes KBCM applications.

For any type of business disruption (firm only, building, business district, citywide or regional) KBCM will leverage its branch network to continue business operations for the affected area or move to an alternate site, with relocated key employees, to continue business operations.

KBCM fully intends to conduct business during times of business disruptions. Every effort will be made to minimize the impact on service to our clients.

During times of service disruptions, KBCM will utilize KeyCorp’s established incident management processes to communicate appropriate information to affected parties. These processes include, but are not limited to, key.com website postings, social media, direct client outreach, e-mail and proprietary call centers.

KBCM's BCP is subject to change. An updated summary will be promptly posted to Key's website. Customers may obtain updated summaries by requesting a written copy of the summary by mail.