Business Continuity Plan Summary

We have prepared, and always maintain a current Business Continuity Plan (“BCP”) in compliance with FINRA Rule 4370. This document outlines our plans to continue business and meet our existing obligations to customers in the event of a Significant Business Disruption (“SBD”). Our BCP is summarized below:

Our firm’s policy is to respond to a 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. We will make every reasonable effort to meet our obligations to customers at all times.

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.

In the event that we determine we are unable to continue the normal conduct of our business, due to any of the scenarios described above, or any other circumstances, we will enact our BCP in order to assure customers prompt access to their funds and securities. Our BCP outlines the back-up facilities and arrangements that will be utilized in these circumstances.

We will make every reasonable effort to continue the conduct of business during any SBD, employing the use of our BCP. We plan to continue the conduct of business during any SBD unless circumstances prohibit us from doing so.

If, for any reason, at any time, we are forced by circumstances outside our direct control to discontinue business, we will immediately determine our planned recovery time and communicate those plans to all concerned parties.

Our BCP is subject to modification, update, and improvement at any time so that we may constantly assure ourselves, our customers, and any other concerned party of our readiness to confront a SBD.

In the event of a SBD, you can contact us at our usual telephone number (914)-714-5129. If you are unable to reach us at that number, you may call an alternative phone number for Rick Panero at (917)-494-2516. Please do not call this number unless there is an SBD. For more information on our BCP, please feel free to contact us.