Business Continuity Program

Overview

Our company has developed a comprehensive business continuity plan that covers the broker-dealer operations of Ameriprise Financial Services, Inc., American Enterprise Investment Services, RiverSource Distributors, Inc., and RiverSource Life Insurance Company (collectively "Ameriprise Financial"). The plan is designed to protect our company from events that threaten the company’s brand, reputation, and financial solvency

The Ameriprise Financial business continuity plan is based upon a proactive, “all hazards” approach towards preparing for business disruptions of varying severity and scope. It provides for testing at least annually and in response to any material changes affecting our business, and takes into consideration critical third-party relationships. Although it is impossible to anticipate every scenario, we believe that our business continuity plan will enable Ameriprise Financial to resume doing business even after the occurrence of events that are most likely to affect business operations.

Key Plan Elements

At Ameriprise Financial Services, we strive to provide our clients with outstanding service that leads to long-term relationships. That is why we have incorporated business continuity planning into our business strategy.

Our “all-hazards” approach includes planning for a multitude of potential threat scenarios, including the possibility of an influenza pandemic. Our goal is to protect our employees’ health and safety while simultaneously mitigating the potential for disruptive business impacts that threaten to undermine our ability to provide service to our clients. As part of our “all hazards” planning, we have developed multiple solution strategies that will enable Ameriprise Financial to recover business operations after experiencing virtually any form of disruption or outage.

Under most scenarios, we expect to continue doing business and resume operations with minimal service impacts. However, under certain scenarios, the time that it takes Ameriprise Financial to recover and to resume operations may be significantly increased depending on the extent of disruption to our systems and the number of personnel affected. A description of our strategies for responding to different types of business disruptions is listed below.

Strategy by Disruption Type

What follows is a description of how Ameriprise Financial will respond to the following four types of disruptions: (1) a firm-only disruption, (2) a disruption that affects a single building, (3) a disruption that affects the entire city or business district, and (4) a disruption that affects the entire Midwest region. We have also included information about how long we expect it will take Ameriprise Financial to recover from these different types of events.

  1. Firm-Only Disruptions
    To respond to a disruption that affects only Ameriprise Financial, such as a computer virus, we have developed an enterprise-wide Crisis Preparedness Plan (CPP) that outlines procedures for proactively addressing life, health, and safety issues; crisis communications; damage assessment; damage mitigation; personnel mobilization; and the protection of mission-critical systems.

    If this type of disruption takes place, Ameriprise Financial intends to restore our clearing (including broker-dealer, retirement services, asset management operations, and all services that support the aforementioned operations) within one day after the disruption occurs. However, unforeseen circumstances could result in lengthier delays during any particular disruption

  2. Disruptions that Affect a Single Building
    In the event of a disruption that affects a single Ameriprise Financial facility, such as a fire in one of our buildings, our plan calls for a response involving multiple alternative locations. We will resume operations by moving key personnel supporting critical business processes to unaffected buildings, to our proprietary back-up facility (if necessary), third-party back-up facilities (if necessary), and to Ameriprise Financial investment management offices (if necessary). Certain operational processes can be performed by having key personnel connect to the Ameriprise Financial network from a remote location. We are also prepared (if necessary) to transfer responsibility for certain operations and support services to our satellite offices.

    We intend to resume operations in all of our business lines within one day after experiencing this type of disruption. However, unforeseen circumstances could result in lengthier delays depending on the building that is affected and the availability of data and applications from our data centers.

  3. Disruptions Affecting the Entire City or Business District
    If a disruption is significant enough to affect the entire city or business district, such as a terrorist attack, we are prepared to recover business operations (including services that support these operations) at both our proprietary and third-party back-up facilities, as well as at certain of Ameriprise Financial investment management offices. As above, certain key employees will work remotely and certain operations and support services would be handled by other Ameriprise Financial offices.

    We intend to resume operations in all of our business lines within one day after a disruption of this nature occurs. However, unforeseen circumstances could result in lengthier delays, depending on the availability of data and applications from our data centers and on the availability of key employees.

  4. Disruptions Affecting an Entire Region
    In the event of a disruption that affects an entire region, such as a regional power outage, we are prepared to recover business operations from third-party back-up facilities, certain of Ameriprise Financial investment management offices and other remote locations that are geographically dispersed from the affected region. In addition, certain of Ameriprise Financial investment management offices as well as Ameriprise Financial satellite offices will take control of portions of Ameriprise Financial business lines. Although Ameriprise Financial intends to resume operations within one day after this type of disruption occurs, it is possible that one of more of our business lines may not be able to resume operations until after the disruption is over.

Recovery Time Variables

In all of the situations described above, Ameriprise Financial expects to continue doing business and expects to resume operations within the specified time frames. However, in the event that a business disruption results in a significant loss of life at our headquarters, or otherwise results in our key employees being unavailable or unable to report to their designated back-up facility, the times to recovery described above may be increased.

Furthermore, although we expect to continue operating irrespective of the type of disruption, it is impossible to anticipate every scenario. Therefore, it is possible that a significant business disruption could result in Ameriprise Financial deciding that we are unable to continue doing business. In those situations, our plan provides procedures to help ensure that our customers have prompt access to their funds and securities.

Enhancements Ongoing

Ameriprise Financial continues to devote substantial resources to the enhancement of our corporate business continuity plan. For example, in addition to our back-up facilities, third-party back-up arrangements and our mainframe data mirroring, we are currently in the process of mirroring our critical data and applications between geographically dispersed data centers to improve our recovery time under each of the situations described above.

We are continuing to assess how our plan takes into consideration third-party relationships. We may also enter into agreements with other firms to perform certain functions on our behalf in the event of a disruption, until we have the capability to resume performing those tasks.

Changes and Modifications

The Ameriprise Financial business continuity plan is subject to modification. We will promptly post information about updates or modifications to the plan on our Web site. You can also obtain updated information about the plan by requesting a written copy by mail. All requests for updated information should be sent to the following address:

Ameriprise Financial
70100 Ameriprise Financial Center
Minneapolis, Minnesota 55474

Addendum — RiverSource Life Insurance Co. of New York Subsidiaries Operating In New York

A subsidiary of RiverSource Life Insurance Co. that operates in New York has implemented business continuity plans that are incorporated into the Ameriprise Financial business continuity program, and address disruptions of varying severity and scope that may affect its operations. This subsidiary intends to resume operations within one day after a disruption occurs, utilizing Ameriprise Financial back-up facilities and personnel located in the Midwest.