Business Continuity Plan

Nuveen, LLC

Business Continuity Plan Summary

This is a summary of the business continuity plans of Nuveen, LLC.  These plans also cover Nuveen Securities, LLC (“the Nuveen broker dealer”), a registered broker dealer and wholly owned subsidiary of the company.  Each affiliate and business area has their own business continuity plan which includes their immediate response plan, business specific recovery procedures, and steps for recovery, restoration and resumption of business processes.

These plans are designed to address a significant business disruption affecting the company’s business operations and sets forth objectives for safeguarding employees; recovering and resuming operations; protecting books and records; and enabling communications with employees, investors, key service providers, and regulators.

These plans cover the company’s business processes and related employees necessary to continue operations during a business interruption. Every aspect of the company’s business is addressed in these plans; including continued investment management; order taking, entry and execution; trade clearance and settlement activities; and rapid communication to key business partners and clients.

The company’s information technology services are provided by our parent company, TIAA.  These technical recovery plans include detailed infrastructure and application recovery procedures necessary to support the restoration and resumption of technology that supports Nuveen’s critical business processes.

The steps taken, pursuant to the plan, are designed to ensure that critical information is captured on a daily basis in a manner that can be accessed by employees from alternate locations. The plan also provides that the company will maintain contacts with regulators during any business interruption and continue to make any necessary regulatory filings.

Whether you are an individual investor, an institutional investor, a financial advisor or a business partner, please be advised that the plan reflects a long-standing commitment of the company and its employees to plan for and be prepared for a significant business disruption.

Investors should note they will continue to have access to their investments through normal channels and the ability to make purchases and sales, despite the fact that Nuveen may be experiencing a business disruption.  Nuveen has certified business continuity plans for key business partners and suppliers, such as our fund transfer agents and custodians.

The company’s goal is to recover its Critical Business Processes with minimal interruption, on the same day, depending on the nature of the disruption.

In conclusion, the company’s plan addresses the steps the company will take to address our response and recovery from a business disruption in a systematic and organized fashion, while realizing that the effects of any disaster are difficult to predict, and the disruption of systems and processes on an industry-wide basis will pose great challenges for any business continuity plan.