Business Continuity Plan

Emergency Contact Persons
Our firm’s two emergency contact persons are:

Edward J. Rappa,
Tel: 212-832-6020
email: erappa@pressprich.com

Dennis C. Hynes
Tel: 212-832-6022
email: dchynes@pressprich.com

Business Description
Our firm conducts business in fixed income securities. 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, which executes our orders, 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 only institutional customers.

Our clearing agents are:

J. P. Morgan Clearing Corp. (JPMCC)
1 Chase Manhattan Plaza
New York, NY 10005-1401
www.jpmorgan.com

Pershing LLC
One Pershing Plaza
Jersey City, New Jersey 07399
www.pershing.com

In the event of a significant business disruption, our customers may contact a JPMCC representative at (212) 552-1919 or Pershing at (201) 413-3635 for liquidating orders, check and wire requests, and ACAT transfers.

Office Locations

New York Location
Our New York Office is located at
520 Madison Avenue 28th Floor
New York, NY 10022.
Its main telephone number is 212-832-6200
Toll Free: 800-627-4091
Fax: 212-832-6288

Boston Location
Our Boston Office is located at 175 Federal Street, 9th Floor
Boston, MA 02110.
Its main telephone number is 617-482-9151
Fax: 617-482-9152

Chicago Location
Our Chicago Office is located at 10 South Riverside Plaza Suite 1826
Chicago, IL 60606.
Its main telephone number is 312-474-7813
Fax: 312-474-6099.

Newport Beach, CA
Our Newport Beach Office is located at 500 Newport Center Drive Suite 580
Newport Beach, CA 92660
Its main telephone number is 949-706-0021
Fax: 949-706-6060

Plymouth, MN
Our Newport Beach Office is located at 15600 36th Avenue N. Suite 140
Plymouth, MN 55427
Its main telephone number is 763-252-1652
Fax: 763-252-1653

Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff from affected offices to any of our other offices at the closest possible location from which we can service our customers.

Customers’ Access to Funds and Securities
Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, JP Morgan Clearing Corporation. In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm on their behalf, and if our Web access is available, our firm will post on our website that customers may contact a JPMCC representative at (212) 552-1919 for liquidating orders, check and wire requests, and ACAT transfers. The firm will make this information available to customers through its disclosure policy.

Mission Critical Systems Provided by Our Clearing Firm
Our firm relies, by contract, on our clearing firm to provide order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.

Alternate Communications Between the Firm and Customers, Employees, and Regulators
We now communicate with our customers using Bloomberg, the telephone, e-mail, fax, U.S. mail, and in person visits at our firm or at the other’s location. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.