Whelan Capital Management and Encinal Capital Group, LLC
Business Continuity Plan Disclosure Statement

Whelan Capital Management (WCM) and Encinal Capital Group, LLC have developed a Business Continuity Plan which focuses on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plans.

Please be advised that Citigroup Global Markets is the Prime Broker for all the Encinal Capital Group accounts. Each segregated client has their own custodian with whom they have a business relationship.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do at (650) 833-7880/gwhelan@wgcm.com, you should call our alternative numbers for Gabe Whelan (650) 722-0258, for Brad Miller (650) 400-1317, or for Adrienne Fioretti (650) 678-3587 or go to our web site at www.wgcm.com. If you cannot access us through any of those means, you should contact your appropriate custodian with any questions. For Encinal Capital Group investors, please consult your subscription agreement.

Our Business Continuity Plans - We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment and protecting the Firm's books and records. In short, our business continuity plans are designed to permit our Firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plans addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

As every emergency situation poses unique problems based on external factors, such as time of day, location of the disaster, and the severity of the disruption, our services could be delayed during this period. Our various custodians may also be affected and could experience a delay in services. However, our custodians back up our important records in geographically separate areas. We have been advised by our custodians that their objectives are to restore their own operations and be able to complete existing transactions and accept new transactions and payments as soon as possible.

Varying Disruptions - Significant business disruptions can vary in their scope, such as only our Firm, a single building housing our Firm, the business district where our Firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our Firm or a building housing our Firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 48 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 48 hours. In either situation, we plan to continue in business and notify you through our web site www.wgcm.com for how to contact us. WCM will also attempt to contact all clients directly. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.

For more information - If you have questions about our business continuity planning, you can contact us at (650) 833-7880

Last Updated: March 2008