Business Continuity Plan

Summary Disclosure Statement

Our firm’s policy 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.

Our plan anticipates two kinds of SBD, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as fire in the building. External SBDs prevent the operation of the securities markets or a number of firms, such as 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 or our clearing firm. Pershing LLC. Our firm does not maintain custody of customer’s funds or securities, which are maintained at our clearing firm or directly with the investment sponsor. In the event of an SBD, either internal or external, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communication options we will employ will include our Web site, telephone voice mail, secure email and postal mail service.

In the event our clearing firm executes its plan, it represents that it will notify us of such execution and provide us equal access to services as its other customers. If we reasonably determine that our clearing firm has not or cannot put its plan in place quickly enough to meet our needs, or is otherwise unable to provide access to such services, our clearing firm represents that it will assist us in seeking services from an alternate source. Our clearing firm has the following SBD recovery time and resumption objectives: recovery time period of four hours for each scenario mentioned above.

This plan is subject to modification, an updated summary will be promptly posted on our Web site and customers may alternatively obtain summaries by requesting a written copy by mail.

For more information - If you have questions about business continuity planning, you can contact us at: 888-896-0020.

Rule: NASD Rule 3510(e).