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Business Continuity Plan

MVV Capital Management LLC

Overview

MVV Capital Management LLC (“MVV Capital Management,” the “Firm,” “we,” or “our”) has adopted this Business Continuity Plan (“BCP”) to address how the Firm will respond to events that significantly disrupt its business operations. Because the timing, scope, and severity of such events are unpredictable, the Firm’s response will vary based on the specific circumstances. This Plan summarizes the Firm’s approach to business continuity and disaster recovery.

Contacting the Firm

In the event of a significant business disruption, clients, counterparties, and service providers may contact the Firm as follows:

If standard communication channels are unavailable, the Firm will use reasonable alternative electronic methods as soon as practicable.

Business Continuity Objectives

The Firm’s Business Continuity Plan is designed to:

  • Protect the safety of personnel
  • Preserve access to Firm data, records, and systems
  • Maintain communication with clients, service providers, and regulators
  • Resume advisory and asset management operations as promptly as reasonably practicable

The Firm’s operations are structured to support continuity through remote access and reliance on third-party infrastructure.

Nature of the Firm’s Business

MVV Capital Management is an Exempt Reporting Adviser under the Investment Advisers Act of 1940. The Firm provides investment advisory and asset management services to private investment vehicles and related clients.

The Firm:

  • Does not maintain custody of client assets
  • Does not hold client funds or securities
  • Does not process client transactions
  • Does not maintain client accounts

Client assets are held with independent custodians, escrow agents, or financial institutions, including banks with which the Firm maintains relationships.

Operational Structure

The Firm operates on a remote-first basis and does not maintain a dedicated physical office location. The Firm maintains a registered agent and virtual office address for administrative and regulatory purposes.

The Firm relies on secure, cloud-based systems for document storage, communication, and operational workflows. This structure reduces reliance on any single physical location and supports continuity in the event of localized disruptions.

Scope of the Business Continuity Plan

The Firm’s BCP addresses the following areas:

  • Data backup and recovery
  • Access to mission-critical systems and records
  • Alternative communication methods
  • Remote work capabilities
  • Dependence on third-party service providers, including custodians, administrators, broker-dealers, and technology vendors
  • Regulatory and client reporting obligations

Varying Types of Business Disruptions

Significant business disruptions may vary in scope, including events affecting only the Firm, individual personnel, local infrastructure, or broader regional or national areas. The severity of such disruptions may range from minimal to severe.

In the event of a disruption limited to the Firm or its personnel, the Firm expects to continue operations remotely and resume normal business activities within approximately 24 hours, subject to circumstances. In the event of a broader disruption, the Firm will rely on its remote infrastructure and third-party service providers to continue operations to the extent reasonably practicable.

If a disruption is so severe that the Firm cannot continue operations for an extended period, the Firm will coordinate, as appropriate, with custodians, fund administrators, broker-dealers, and other service providers to facilitate continued client access to information and services.

Data Protection and Recordkeeping

The Firm maintains required books and records in electronic format using secure, cloud-based systems with routine data backup procedures. These records are accessible remotely and can be restored in the event of a system failure or disruption.

Regulatory Communication

As an Exempt Reporting Adviser, the Firm will communicate with applicable federal and state regulatory authorities as required under the Investment Advisers Act of 1940 and other applicable laws in the event of a significant business disruption.

Plan Maintenance and Review

The Firm reviews its Business Continuity Plan periodically and updates it as necessary to reflect changes in the Firm’s operations, service providers, or regulatory obligations.

Additional Information

Questions regarding this Business Continuity Plan may be directed to:

MVV Capital Management LLC
compliance@mvvcm.com
www.mvvcapitalmanagement.com

Important Disclosure: MVV Capital Management operates as an Exempt Reporting Advisor (ERA). This website is for informational purposes only and does not constitute an offer to sell or a solicitation to buy any securities. All investments involve risk, including the potential loss of principal. Past performance does not guarantee future results. Information presented herein is subject to change without notice. Prospective investors should carefully review all offering documents and consult with their financial, legal, and tax advisors before making any investment decision.