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

XIV. 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, in January, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm.