I. Emergency Contact Persons II. Firm Policy III. Business Description IV. Office Location V. Alternative Physical Location(s) of Employees VI. Customers’ Access to Funds and Securities VII. Data Back-Up and Recovery (Hard Copy and Electronic VIII. Financial and Operational Assessments IX. Mission Critical Systems X. Alternate Communications Between the Firm and Customers, Employees and Regulators XI. Critical Business Constituents, Banks, and Counter-Parties XII. Regulatory Reporting XIII. Disclosure of Business Continuity Plan XIV. Updates and Annual Review XV. Senior Manager Approval

III. Business Description

Our firm conducts business in equity, exchange-traded options and fixed income. Our firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders. All transactions are sent to our clearing firm, Mesirow Financial, Inc. which compares them, allocates them, clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services retail customers and institutional customers. We do not engage in any private placements.

Our clearing firm is:
Mesirow Financial, Inc.
350 N Clark Street
Chicago, Illinois 60610
312/595-6000
www.mesirowfinancial.com
and our
contact person at that clearing firm is:
Client Services Department
1-800-552-2491, Ext. 7007 or email at
clientservices@mesirowfinancial.com.

Our clearing firm has also given us the following emergency contact in the event it cannot be reached at 1-866-401-6200.