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Disclosure of Business Continuity Plan

As a registered broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA), First Trust Portfolios L.P. is required to provide certain disclosures to our customers regarding the nature of our Business Continuity Plan, and how we would expect to respond to Significant Business Disruptions (SBDs) of varying severity.

First Trust Portfolios L.P. (FTP) has developed a comprehensive Disaster Recovery Plan which is routinely tested on an ongoing basis. The Plan is designed to allow FTP to quickly resume operations in the event on an SBD. A key element of the Plan is a back-up site which is configured with computers, phones, copiers, fax machines, and printers. Furthermore, the back-up site is located on a separate power and phone grid than FTP's main office in Wheaton, IL. All necessary software and back-up records are maintained at the site to facilitate servicing customers and processing transactions. FTP senior management will assess the nature and severity of an SBD to determine whether operations should be moved to the back-up site.

We believe that we will be able to resume operations and continue in business under most SBD scenarios. Certain potential SBD situations which FTP has considered are described below.

  • A disruption affecting only FTP's main office in Wheaton, IL or a disruption affecting the building in which FTP has it's main office. Examples of such events would include a fire or explosion in FTP's offices or elsewhere in the building, a local power outage affecting FTP's offices, a chemical or biological alert affecting the building, or any other event which might result in the need to evacuate FTP's office facilities. FTP's response to such events would be to analyze the situation and determine whether to move operations to the back-up site. If FTP senior management determines that it is safe to occupy FTP's offices (for example if the SBD has merely caused the loss of electrical power), FTP would continue to conduct business from it's main office using back-up generators; in such an event FTP's recovery time would be virtually instantaneous. If it is determined that it is not safe to occupy FTP's offices, operations would be moved to the back-up site. In such an event, we believe we would be able to resume most of our normal operations and conduct business later that day or by the next business day.
  • A disruption affecting the Wheaton, IL business district or affecting the City of Wheaton, IL (possibly including the surrounding area as well). Examples of such events would include a power outage affecting the entire area, a chemical or biological alert forcing evacuation of the area, severe weather damage affecting the area (e.g. a tornado), or any other event which might result in the evacuation of FTP's offices. We anticipate that our response to such events would be the same as that previously described above.
  • A regional disruption affecting both FTP's main office and the back-up facility. Such a disruption may affect the Chicago Metropolitan area, the entire State of Illinois, or possibly a multi-state area. Examples of such events would include a large-scale power outage such as that experienced in the Northeast portion of the United States in August 2003, a large-scale terrorist attack or other Act of War affecting the region, or a large-scale natural disaster. In such situations, FTP would continue operations from either our main office or the back-up site, assuming that one or the other location is judged to be safe. If it is determined that neither location is safe to occupy, FTP would be unable to conduct business. Should such a situation occur, FTP would resume operations as quickly as possible.

This information is intended to generally describe the steps which FTP would take in response to various SBD scenarios. However, due to the inherent uncertainties involved, no assurance can be given as to whether FTP's efforts to continue operations will be successful. This document may be modified in the future and any such updates will be promptly posted on our website at www.ftportfolios.com. You may also request an updated copy by calling 1-800-621-1675.