Business Continuity Plan Disclosure

POD SECURITIES, LLC

Business Continuity Plan (BCP)

FINRA Rule 4370 requires member firms to create and maintain a Business Continuity Plan (BCP) identifying procedures relating to any significant business disruption to the member’s business that are reasonably designed to enable the member to meet its existing obligations to its customers. In addition, BCP procedures must address existing relationships with clearing firms (if any), regulators and other vendors that are critical to the operation of its business.

This plan has been developed to address the rule requirements under FINRA Rule 4370 and 3520 related to Business Continuity Procedures of Pod Securities. It is designed to facilitate the communication and implementation of emergency procedures in the event of a significant business disruption. The BCP is designed to account for business interruptions of various lengths and scope and ensure that Pod Securities is able to recover critical functions according to their time criticality. It is designed to be a permanent record which will be reviewed and/or updated at least annually or at any time that substantially changes in the business activities of Pod Securities would otherwise necessitate such a review.

Emergency Contact Persons

The Firm’s emergency contacts are:

Name: Eli Wishnivetski Phone: (646) 522-6175

Email: eli@flycraft.com

Name: Joel Kleiner Phone: (786) 606-5136

Email: joel@flycraft.com

These names will be updated in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each quarter.

Firm Policy

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.

• Significant Business Disruptions (SBDs)

  Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.
  
  

• Approval and Execution Authority

  Eli Wishnivetski, a registered principal, is responsible for approving the plan and for conducting the required annual review. Eli Wishnivetski has the authority to execute this BCP.
  
  

• Plan Location and Access

  Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan will be located on a cloud server.
  
  

Business Description

Our firm conducts business as a private placement agent is the securities industry. Our firm does not open, hold or introduce accounts for any “customer,” do not perform any type of clearing function for itself or others, nor we accept and enter orders. As a result, any SBD impact on our firm will be minimal to non-existent. Private placement transactions are not time-reliant and, therefore, are necessarily impacted by a potential SBD.

Alternative Physical Location(s) of Employees

In the event of an SBD, we will move our staff from affected office(s) to their private residences, or other private locations associated with the staff. Staff has the ability to

work remotely and will have access to any books and records of the Firm. Staff will operate through the local internet connections and their mobile phones.

Customers’ Access to Funds and Securities

Our firm does not transact in or maintain custody of customers’ funds or securities, which will be maintained at our clearing firm.

Data Back-Up and Recovery (Hard Copy and Electronic)

Our firm maintains its books and records electronically on a shared cloud server, which will not be affected in the case of a SBD. Our firm will maintain its back-up electronic copy of its books and records on a zip drive to be maintained by its CCO. The Firm will not create or maintain hard copy records.

Rule: FINRA Rule 3510(c)(1).

Financial and Operational Assessments

• Operational Risk

  In the event of an SBD, we will immediately identify what means will permit us to communicate with our prospective investors and issuers, employees, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include telephone and e-mail. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery.

  Rules: FINRA Rule 4370(c)(3) & (f)(2).
  
  

• Financial and Credit Risk

  A SBD will affect our ability to continue to fund our operations and remain in capital compliance.

  Rules: FINRA Rule 4370(c)(3), (c)(8) & (f)(2).
  
  

Mission Critical Systems

Our firm business is that of a private placement agent. As such, there are no “mission critical systems” utilized by the Firm.

Rules: FINRA Rule 4370(c) & (f)(1).

Alternate Communications Between the Firm and Customers, Employees, and Regulators

• Customers

  We communicate with our prospective investors and issuers using the telephone, e-mail, our Web site, fax, U.S. mail, and in person visits at our firm or at the other’s location. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.

  Rule: FINRA Rule 4370(c)(4).
  
  

• Employees

  We communicate with our employees using the telephone, e-mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral).

  Rule: FINRA Rule 4370(c)(5).
  
  

• Regulators

  The Firm is subject to regulatory oversight by the SEC, FINRA, and other state regulators. We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

Rule: FINRA Rule 4370(c)(9).

Critical Business Constituents, Banks, and Counter-Parties

• Business constituents

  If the Firm will have any critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), the Firm will determine the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm.

  Rules: FINRA Rule 4370(c)(7).
  
  

• Banks

  A SBD will not affect our relationship with our bank and lenders (if any). The Firm will require financing as a result of any SBD.

  Rules: FINRA Rule 4370(c)(7).
  
  

• Counter-Parties

  The Firm will not have any counter-parties due to its business model.

Rules: FINRA Rule 4370(a) &(c)(7).

Regulatory Reporting

Our firm is subject to regulation by: SEC, FINRA, and other state regulators and may file reports with our regulators using paper copies in the U.S. mail or electronically using fax, e-mail, and the Internet. In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

Rule: FINRA Rule 4370(c)(8).

Disclosure of Business Continuity Plan

The Firm does not have any “customers” or “accounts” to which a written BCP disclosure statement will be owed.

Rule: FINRA Rule 4370(e).

Updates and Annual Review

Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our firm will review this BCP annually to modify it for any changes in our operations, structure, business or location.

Rule: FINRA Rule 4370(b).

Senior Manager Approval

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.

Rule: FINRA Rule 4370(d).

Signed: Eli Wishnivetski

Title: CEO

Date:2/15/2026