We plan to quickly recover and resume business operations after a significant business disruption and respond by:

• safeguarding our employees and property;
• making a financial and operational assessment;
• protecting the firm’s books and records; and
• allowing our customers to transact business.

In short, our Business Continuity Plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our plan addresses:

• data backup and recovery;
• all mission critical systems;
• financial and operational assessments;
• alternative communications with customers, employees, and regulators;
• alternate physical location of employees;
• critical supplier, contractor, bank and counter-party impact; and
• regulatory reporting.

Our U.S. securities trading clearing firm, Pershing LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our U.S. securities trading clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. Your orders and requests for funds and securities could be delayed during this period.

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to our firm or a building housing our firm, or a disruption affecting our business district, we will transfer our operations to our local disaster recovery site when needed and expect to recover and resume business within sixty (60) minutes. In either situation, we plan to resume business, transfer operations to our clearing firm only if absolutely necessary, and notify you through our web site or our customer emergency number, (514 932-8948 or 1-877-932-7171).

If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our institutional customers have prompt access to their accounts.