Disaster Recovery Plan Summary

This is a summary of the immediate and long-term contingency planning and recovery process of Santa Barbara Asset Management (“SBAM”). The purpose of a Disaster Recovery Plan (“DRP”) is to provide specific guidelines the firm will follow in the event of a failure of any critical business capability. The Company’s parent, Nuveen Investment, Inc. and its affiliates (collectively, “Nuveen”) have adopted similar plans to address significant business interruptions affecting operations at their offices in Chicago, IL, Radnor, PA, Los Angeles, CA and San Francisco, CA.

The goal of the DRP is to provide uninterrupted service to our clients or to minimize the downtime should a system or vendor failure occur. The DRP has been developed to meet the following objectives:

• Provide for immediate, accurate and measured response to emergency situations;
• Minimize the impact upon the safety and well being of firm personnel;
• Protect against the loss or damage to organizational assets;
• Provide our clients with alternative site processing with a minimum of inconvenience.

Risk assessment, disaster prevention, and disaster avoidance are critical components of SBAM’s contingency planning process. The implementation of this DRP should help to ensure all data processing systems, data communication facilities, information, data and business functions can be restored in a secure manner. Restoration must be accomplished in a time frame consistent with legal, regulatory and business requirements while maintaining information integrity.

In order to maintain operations during the commencement of a significant emergency or disaster, SBAM will ensure all of the firm’s personnel are contacted to confirm their well-being and to provide information about altered work arrangements. Arrangements have been made to provide alternative physical facilities for employees to use in the event SBAM’s primary facilities become unusable.

SBAM’s contingency planning process includes a number of procedures to ensure that critical information is captured on a daily basis in a manner that can be accessed by employees from remote or alternate locations. All of the most important aspects of the Company’s advisory business, including continued investment management and trading of institutional and separately managed account portfolios, mutual funds and other portfolios and rapid communication to key business partners and clients, are addressed in these processes. SBAM takes very seriously its obligation to protect information and allow access to backup sources of information in the event of a disaster.

In conclusion, SBAM’s DRP addresses the steps the Company will take to address a temporary business disruption in a systematic and organized fashion. Of course, the effects of a disaster are difficult to predict and the disruption of the systems and processes on an industry wide basis will pose great challenges for any continuity plan. There can be no assurance that any plan can address such unforeseen contingencies.