Business Continuity Plan



Securities industry regulations require that brokerage firms inform their clients of their plans to address the possibility of an unplanned significant business disruption (“SBD”) resulting from, among other things, extraordinary events such as power outages, building evacuations, natural disasters, acts of terrorism or other catastrophes. Cuttone & Co., LLC. has a comprehensive business continuity plan (“BCP”) in place, which we review, update and test at least annually.

In general, we conduct our business at multiple locations. Our BCP is designed to ensure that if one of our locations or means of communication suffers a disruption in service, our other locations or communications systems can cover our critical business functions, including order acceptance, entry and execution. As a result, in the event that an SBD impacts a particular location, we intend to rely on the personnel and systems at our other locations so that both we and our customers can continue to conduct business with minimal, if any, interruption. For example, during any SBD, we intend to continue to (i) accept orders via telephone, email, instant messaging or fax, as available, (ii) enter orders in person, electronically or telephonically, as available, and (iii) execute orders via hand, electronic order system or other available means. In addition, we will immediately identify any available means that will permit us to communicate with our clients, employees, critical business constituents, banks, counter-parties and regulators.

For any SBD, we have plans and teams in place to address our immediate response to and management of the incident as well as a business unit and information technology recovery plan. For each of these teams, we have plans to address situations where one of our locations (including the technology based at such location) becomes unavailable for any reason, as well as when a technology or other service provider ceases to operate for any reason. Whatever the event, our BCP is designed to enable us to be back in operation within 24 hours.

In designing our BCP, we have assumed that, during an SBD, our alternative locations are available and accessible, we have sufficient personnel, and external organizations, such as government agencies and market systems, are operational. If this turns out not to be the case, our business could be significantly disrupted until such external matters are resolved.