Nutmeg Securities LTD Business Continuity Planning

Nutmeg Securities Ltd Business Continuity Planning
Nutmeg Securities Ltd has developed a Business Continuity Plan on how we will respond to
events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is
unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are
providing you with this information on our business continuity plan.
Contacting Us – If after a significant business disruption you cannot contact us as you usually
do at 800-288-5513, you should call our alternative number 203-255-3838 or go to our web site at
www.nutmegsecurities.com for information. If you cannot access us through either of those means, you should
contact our clearing firm, Pershing, www.pershing.com/about.htm or call 201-413-3635 for recorded
instructions. If you cannot access the instructions from the website or the previously noted telephone number,
Pershing may be contacted at 213-624-6100 extension 500 as an alternate telephone number for recorded
instructions.
Our Business Continuity Plan – 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 business continuity plan addresses: data back up 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; regulatory
reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue
our business.
Our clearing firm, Pershing, 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 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 hours. Your orders
and requests for funds and securities could be delayed during this period. This recovery objective may be
negatively affected by the unavailability of external resources and circumstances beyond our control. Also,
instructions to our clearing firm, Pershing, must be in writing and transmitted via facsimile (201)-413-5368 or
postal service as follows:
Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065
Varying Disruptions – 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 only our firm or a building housing our firm, we will transfer our operations to a local site
when needed and expect to recover and resume business within 24 hours. In a disruption affecting our business
district, city, or region, we will transfer our operations to a site outside of the affected area, and expect to recover
and resume business within 48 hours. In either situation, we plan to continue in business, transfer operations to
our clearing firm if necessary, and notify you through our web site www.nutmegsecurties.com or our customer
number, 800-288-5513. If the significant business disruption is so severe that it prevents us from remaining in
business, we will assure our customer’s prompt access to their funds and securities by directing you to contact
our clearing firm directly.
For more information – If you have questions about our business continuity planning, you can contact us at:
Nutmeg Securities Ltd

1960 Bronson Road
Building Two
Fairfield, CT 06824
1-800-288-5513
info@nutmegsec.com
proprietary and confidential 2

Nutmeg Securities Ltd
Business Continuity Plan (BCP)
I.Emergency Contact Persons

Our firm’s two emergency contact persons are:
Mathew Rochlin
Office: 203-255-3838
Home: 203-256-1437
VT Home: 802-325-2501
Cell: 203-7639326
EMAIL: mkr@nutmegsec.com alternate finopco@yahoo.com
Marissa Santangelo
Office: 203-255-3838
Home: 203-856-5702
Cell: 203-856-5702
EMAIL: Marissa@nutmegsec.com alternate MSanta7710@aol.com
These names will be updated in the event of a material change, and our Executive Representative
will review them within 17 business days of the end of each quarter.
Rule: NASD Rule 3520.

II.Firm Policy
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding

employees’ lives and firm property, making a financial and operational assessment, quickly recovering
and resuming operations, protecting all of the firm’s books and records, and allowing our customers to
transact business. In the event that we determine we are unable to continue our business, we will
assure customers prompt access to their funds and securities.
A.Significant Business Disruptions (SBDs)

Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s
ability to communicate and do business, such as a fire in our building. External SBDs prevent the
operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a
wide-scale, regional disruption. Our response to an external SBD relies more heavily on other
organizations and systems, especially on the capabilities of our clearing firms.
B.Approval and Execution Authority

Marissa Santangelo, Chief Compliance Officer is responsible for approving the plan and for
conducting the required annual review. Mathew Rochlin, President has the authority to execute this
BCP.
C.Plan Location and Access

Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been
made to it for inspection at each branch office location. An electronic copy of our plan is located on
Nutmeg’s server in the Compliance folder .
III.Business Description
Our firm conducts business in equity, fixed income, and derivative 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 firms, 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 retail and institutional customers.
Our clearing firm is:

Pershing LLC
PO Box 2065
Jersey City, NJ
TEL: 800-443-4342 or 201-413-4017

Contact: Lauren DeAngelis, LDeAngelis@pershing.com
Webpage: www.pershing.com
IV.Office Locations
Office Locations
Office Location #1 Head Office - Nutmeg Securities Ltd
Our Location #1 Office is located at 1960 Bronson Road, Building Two, Fairfield, CT 06854. Its main
telephone number is 800-288-5513. Our employees may travel to that office by means of foot, car,
train, and taxi. We engage in order taking and entry at this location.
Office Location #2 - Nutmeg Securities Ltd
Our Location #2 Office is located at 1333 Broadway, 6th Floor Suite 622, New York, NY 10018. Its
main telephone number is 888-640-1007. Our employees may travel to that office by means of foot,
car, train, and taxi. We engage in order taking and entry at this location.
Office Location #3- Nutmeg Securities Ltd
Our Location #3 is located at One Financial Place, 440 S. LaSalle St, 4th Floor, Chicago, IL 60605. Its
Office Location #4 – Future Benefits

Our Location #4 is located at 1781 Highland Ave, Suite 205, Cheshire, CT 06410. Its main telephone
number is 800-272-4745. Our employees may travel to that office by means of foot, car, train, and taxi.
We engage in order taking and entry at this location.
Office Location #5 – Heritage Benefits Consultants
Our Location #5 is located at 680 Main Street Water Town, CT 06795 and 10 Water Street, Mystic,
CT 06355. Its main telephone number is 860-945-6043. Our employees may travel to that office by
means of foot, car, train, and taxi. We engage in order taking and entry at this location.
Office Location #6 – Spectrum Financial Strategies, Inc.
Our Location #6 is located at 2764 Whitney Ave, Second Floor, Hamden, CT 06518. Its main
Office Location #7 – Advisors One, LLC
Our Location #7 is located at 153 South Main Street, Newtown, CT 06470. Its main telephone number
is 203-270-7700. Our employees may travel to that office by means of foot, car, train, and taxi. We
engage in order taking and entry at this location.
Office location #8 - Nutmeg Securities Ltd
Our office Location #8 is located at 553 Monarch Ridge Drive, Walnut Creek, CA 94597. Its main
Office Location # 9 - Nutmeg Securities Ltd
Our Office Location #9 is located at 1855 Olympic Blvd, Suite 165, Walnut Creek, CA 94596. Its

Our Office location #10 is located at One Turks head Place, Suite 203, Providence, RI 02903. Its main
. Office Location # 11– Nutmeg Securities Ltd
Our Office Location #11 is located at 147 East Road, Alford, MA 01266. Its main telephone number is
888-862-7407. Our employees may travel to that office by means of foot, car, train, and taxi. We
engage in order taking and entry at this location.
Office Location # 12 – Freedom Financial
Our Office Location # 12 is located at 859 Tunxis Hill Road, Fairfield, CT 06825. Its main telephone
We engage in do not order taking and entry at this location.
Office Location # 13 – Metro Pension Analysts Ltd.
Our Office Location # 17 is located at 2235 Corte Cicuta, Carlsbad, and CA 92009. Its main telephone
We do not engage in order taking and entry at this location.
Our Office Location #19 is located at 24 Thorpe Street, Fairfield, CT 06824. Its main telephone
Office Location #14 – Advanced Benefit Strategies
Our Office Location 14 is located at 30 Mill Street, Unionville, CT 06085. Its main telephone number
is 860-675-4227. Our employees may travel to that office by means of foot, car, train, and taxi. We do
not engage in order taking and entry at this location.

Our Office Location #15 is located at 2335 Diamond J Place, Reno, NV 89511. Its main telephone
We engage in order taking and entry at this location.
Office Location #16 – Nutmeg Securities Ltd
Our Office Location #16 is located at 7 Academy Street, Salisbury, CT 06068. Its main telephone
Office Location # 17- Nutmeg Securities Ltd
Our Office Location #26 is located at 20 Juniper Place, Wilton, CT 06897. Its main telephone number
is 203-761-1502. Our employees may travel to that office by means of foot, car, train, and taxi. We do
not engage in order taking and entry at this location.
Our Office Location # 18is located at 504 Pleasant Street, Somerset, MA 02726. Its main telephone
number is 508-646-3783. Our employees may travel to that office by means of foot, car, train, and
taxi. We do not engage in order taking and entry at this location.
Office Location # 19 - Nutmeg Securities Ltd
Our Office Location # 19 is located at 132 Bacon Road, Roxbury, CT 06783. Its main telephone
Office Location # 20- Nutmeg Securities Ltd

Our Office Location #31 is located at 1821 Mooring Line Drive, Apt 2A, Vero Beach, FL 32963. Its
car, train, and taxi. We do not engage in order taking and entry at this location.
Office Location # 21– Nutmeg Securities Ltd
Our Office Location #21 is located at 5 Deer Run Circle, S. Londonderry, VT 05155. Its main
telephone number 802-824-8184. Our employees may travel to that office by means of foot, car, train,
and taxi. We do not engage in order taking and entry at this location.
V.Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff from affected offices to the closest of our unaffected
office locations. If none of our other office locations is available to receive those staff, we will move
them to our back up site located at 135 Redding Road, Easton CT main telephone number is 203-256-
1437.
Rule: NASD Rule 3510(c)(6).
VI. Customers’ Access to Funds and Securities

.
Our firm does not maintain custody of customers’ funds or securities, which are maintained at our
clearing firms: Pershing LLC .
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 Web site that customers may access their funds and
securities by contacting available functional office locations .Alternate methods will be posted if
required, such as directions to telephone, or if unavailable, use email, facsimile or other method to
contact the clearing firm directly. The firm will make this information available to customers through
its disclosure policy.
If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities
exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a
trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books
and records identifying customer accounts subject to SIPC regulation.
Rules: NASD Rule 3510(a); Securities Exchange Act Rule 15c3-1; 15 U.S.C. 78eee (2003).
VII.Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records and its electronic records at 1960 Bronson
Road, Fairfield, CT 06824. Dale Brown, Office Manager, 203-255-3838 is responsible for the
maintenance of these books and records. Many primary records are transmitted to our clearing firm
and are retrievable .Our firm maintains other documents and forms that are not transmitted to our
clearing firm which are listed on Exhibit A, attached.
Our firm maintains its back-up hard copy books and records. These records may be in paper or
electronic format. Dale Brown, Office Manager, 203-255-3838 is responsible for the maintenance of
these back-up books and records. Our firm backs up its paper records by copying and taking them to
our back-up site. Electronic records are backed up by tape drive, which is taken to our back up site
daily.
In the event of an internal or external SBD that causes the loss of our paper records, we will physically
recover them from our back-up site. If our primary site is inoperable, we will continue operations from
our back-up site or an alternate location. For the loss of electronic records, we will either physically
recover the storage media or electronically recover data from our back-up site, or, if our primary site is
inoperable, continue operations from our back-up site or an alternate location.
Rule: NASD Rule 3510(c) (1).
VIII.Financial and Operational Assessments
A.Operational Risk

In the event of an SBD, we will immediately identify what means will permit us to best communicate
with our customers, employees, critical business constituents, critical banks, critical counter-parties,
and regulators. Although the effects of an SBD will determine the means of alternative
communication, the communications options we will employ will include our website, telephone
voicemail, regular telephone and secure email. In addition, we will retrieve our key activity records as
described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).
Rules: NASD Rules 3510(c)(3) & (f)(2).
B.Financial and Credit Risk
In the event of an SBD, we will determine the value and liquidity of our investments and other assets
to evaluate our ability to continue to fund our operations and remain in capital compliance. We will
contact our clearing firm, critical banks, and investors to apprise them of our financial status. If we
determine that we may be unable to meet our obligations to those counter-parties or otherwise continue
to fund our operations, we will request additional financing from our bank or other credit sources to
fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will
file appropriate notices with our regulators and immediately take appropriate steps, including
appropriate notification and release of relevant information to all interested parties.
Rules: NASD Rules 3510(c)(3), (c)(8) & (f)(2).
IX.Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of
securities transactions, including order taking, entry, execution, comparison, allocation, clearance and
settlement of securities transactions, the maintenance of customer accounts, access to customer
accounts, and the delivery of funds and securities. More specifically, these systems include:
MASLOW : Electronic trading system

NETXPRO : Pershing proprietary trading/client account information system
We have primary responsibility for establishing and maintaining our business relationships with our
customers and have sole responsibility for our mission critical functions of order taking and entry and
execution. Our clearing firm provides, through contract, the comparison, allocation, clearance and
settlement of securities transactions, the maintenance of customer accounts, access to customer
accounts, and the delivery of funds and securities.
Our clearing firm contracts provide that our clearing firms will maintain business continuity plans and
the capacity to execute those plans. Our clearing firm represents that they will advise us of any
material changes to its plan that might affect our ability to maintain our business [and presented us
with an executive summary of such plans, which are attached]. In the event our clearing firm executes
its plan, it represents that it will notify us of such execution and provides us equal access to services as
its other customers. If we reasonably determine that our clearing firm has not or cannot put its plan in
place quickly enough to meet our needs, or is otherwise unable to provide access to such services, our
clearing firm represents that it will assist us in seeking services from an alternative source.
Our clearing firm represents that they back up our records at alternate remote sites. Our clearing firm
represent that they operate a back-up operating facility in a geographically separate area with the
capability to conduct the same volume of business as its primary site. Our clearing firm has also
confirmed the effectiveness of its back-up arrangements to recover from a wide scale disruption by
testing (and it has confirmed that it tests its back-up arrangements every quarter at Pershing).
Recovery-time objectives provide concrete goals to plan for and test against. They are not, however,
hard and fast deadlines that must be met in every emergency situation, and various external factors
surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure—
particularly telecommunications—can affect actual recovery times. Recovery refers to the restoration
of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to
accept and process new transactions and payments after a wide-scale disruption. Our clearing firm has
the following SBD recovery times and resumption objectives: recovery time period of 4 hours at
Pershing and resumption time of four hours at Pershing.
A.Our Firm’s Mission Critical Systems

1.Order Taking
Currently, our firm receives orders from customers via telephone/fax/ electronically or in person visits
by the customer. During an SBD, either internal or external, we will continue to take orders through
any of these methods that are available and reliable, or in addition, as communications permit, we will
inform our customers what alternatives they have to send their orders to us. Customers will be
informed of alternatives by voicemail, webpage notification (www.nutmegsecurities.com ) email or
telephone. If necessary, we will advise our customers to place orders directly with our clearing firm at
Pershing LLC
P.O. Box 2065
Jersey City NJ 07303
Tel: 201-413-3635
Alternate: 213-624-6100 extension 500
Facsimile: 201-413-413-5368
2.Order Entry
Currently, our firm enters orders by recording them on paper and electronically and by sending them
to our clearing firms electronically or telephonically. Additionally, we may place customer orders
through MASLOW electronic trading system. We have contacted MASLOW and were told that, under
its BCP, we can expect resumption of trading ability within one business day (BCP Plan questionnaire
attached).
In the event of an internal SBD, we will enter and send records to our clearing firm by the fastest
alternative means available, which include telephone, email, facsimile, US Post or messenger service.
In the event of an external SBD, we will maintain the order in electronic or paper format, and deliver
the order to the clearing firm by the fastest means available when it resumes operations. In addition,
during an internal SBD, we may need to refer our customers to deal directly with our clearing firm for
order entry.
3.Order Execution
We currently execute orders by use of trading systems described above; these systems depend on the
functionality of clearing firms. In the event of an internal SBD, we would temporarily relocate our
staff to the nearest office location with the equipment necessary to perform trade execution functions
(see office location list above). In the event of an external SBD, we would move employees to the
respective closest functioning office location, if none was available we would transfer key staff to the
Easton back-up site and if none of these options were feasible we would direct clients to place orders
directly with our clearing firms by use of all available means (email, webpage notification, telephone,
US post).
4.Other Services Currently Provided to Customers
In addition to those services listed above in this section we also sell mutual funds and some annuity
products. In the event of an internal SBD, we would rely on the methods described above to continue
to perform these functions. In the event of an external SBD, we would rely upon the methods described
above and if deemed necessary advise clients by webpage, voicemail, telephone or US POST to
contact their respective clearing firm/mutual fund/insurance company directly to ensure they are able
to transact business and have access to funds.
B.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.
Rules: NASD Rules 3510(c) & (f)(1).
X.Alternate Communications Between the Firm and Customers, Employees, and

Regulators
A.Customers
We now communicate with our customers using the telephone, e-mail, our Web site, fax, U.S. mail,
and in person visits at our firm. 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. For example, if we have communicated
with a party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up
where a record is needed with paper copy in the U.S. mail.
B. Employees
We now communicate with our employees using the telephone, e-mail, and in person. 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. We will also employ a call tree so that senior management can reach all
employees quickly during an SBD. The call tree includes all staff home and office phone numbers.
We have identified persons, noted below, who live near each other and may reach each other in person:
The person to invoke use of the call tree is: Mathew Rochlin
Caller Call Recipients

Matthew Rochlin Marissa Santangelo
Cathy Mayberry
Dale Brown
Marissa Santangelo Christina Alvarado

Richard Salter
Bob Mahoney
Fran Turiano
Richard Brown
Robert Delbuono
Cathy Mayberry Shaneka Shuler

Evelyn Conejo
Tina Mauro
Dale Brown Hans Kummerfeld

Tim Manning
Tom Doyle
Tom Hiten
Mark Kennedy
Andrew Harris
Ray Mastro
Barbara Dunlap
Patricia Weber
Steve Bliss
DJ Geils
Rich Mahoney
Steve Marchese
Bryan Bogen
Ed Perry
Rocco Marciano
Caller Call Recipients

Christina Alvarado Eileen McEntyre
Dan Hornbuckle
Andrew Schopick
Jean Orr
Peter Labe
Tony Hoag
Dan Haines
Tom Hiten Kevin Grenham

Steve Repka
William Doran
John Donadio
Phil Coco
Bryan Bogen Vincent Falade
Ed Perry John Aitken

Louis Ragosta
Kristen Cambio
John Aitken
C. Regulators
We are currently members of the following SROs:
MSRB
703-797-6600
1900 Duke Street
Suite 600
Alexandria, VA 22314
NASD
617-532-3400
617-451-3524 Fax

99 High Street
Suite 900
Boston, MA 02110
George Malley
SEC
617-454-5900
73 Tremont Street
Suite 600
Boston, MA 02108
Marc Gera
geram@sec.gov
State Of Connecticut
860-240-8245
260 Constitution Plaza
Hartford, CT 06103
Salvatore Cannata
salvatore.cannata@po.state.ct.us
We are also responsible for reporting to the following State Regulators as we conduct business in these
States;
Alabama
Securities Commission
770 Washington Avenue
Suite 570
Montgomery, AL 36130-4700
(334) 242-2984 (800) 222-1253
(334) 242-0240 (Fax)
asc@asc.state.al.us
www.asc.state.al.us/

Joseph P. Borg, Esq.
Director
(334) 242-2386
jborg@asc.state.al.us
Alaska
Dept. of Community and Economic Dev.
Div. of Banking, Securities & Corporations
State Office Building
150 Third Street, Room 217
Juneau, AK 99811-0807
P.O. Box 110807

Juneau, AK 99811-0807
(907) 465-2521
(907) 465-2549 (Fax)
www.dced.state.ak.us/bsc/secur.htm
Mark R. Davis
Director
mark_davis@dced.state.ak.us
Arizona
Corporation Commission
Securities Division
1300 West Washington Street
Third Floor
Phoenix, AZ 85007
(602) 542-4242
(602) 594-7470 (Fax)
accsec@ccsd.cc.state.az.us
www.ccsd.cc.state.az.us/
Matthew J. Neubert
Director
(602) 542-0605
(602) 594-7451 (Fax)
mn@ccsd.cc.state.az.us
Arkansas
Securities Department
Heritage West Building
201 East Markham, Room 300

Little Rock, AR 72201-1692
(501) 324-9260
(501) 324-9268 (Fax)
arsec@ccon.net
www.state.ar.us/arsec/
Michael Johnson
Securities Commissioner
michael.johnson@mail.state.ar.us
California
Department of Corporations
1515 K Street
Suite 200
Sacramento, CA 95814
(916) 445-7205
(916) 445-7975 (Fax)
www.corp.ca.gov
William P. Wood
California Corporations Commissioner
(916) 324-9011
Timothy L. Le Bas
Assistant Commissioner & General Counsel
Office of Law & Legislation
Colorado
Division of Securities
1580 Lincoln Street
Suite 420
Denver, CO 80203
(303) 894-2320
(303) 861-2126 (Fax)
www.dora.state.co.us/securities
Fred J. Joseph
fred.joseph@dora.state.co.us

Delaware
Department of Justice
Carvel State Office Building
820 North French Street, 5th Fl.
Wilmington, DE 19801
(302) 577-8424
(302) 577-6987 (Fax)
syackoski@state.de.us
www.state.de.us/securities/index.htm
James B. Ropp
(302) 577-8925
jropp@state.de.us
District of Columbia
Department of Insurance &
Securities Regulation
Securities Bureau
810 First Street, NE
Suite 622
Washington, DC 20002
(202) 727-8000
(202) 535-1199 (Fax)
www.disr.washingtondc.gov
Theodore A. Miles
Director, Securities Bureau
(202) 442-7800
theodore.miles@dc.gov
Florida
Office of Financial Regulation
200 East Gaines Street
The Fletcher Building
Tallahassee, FL 32399-0372
(850) 410-9805
(850) 410-9748 (Fax)
www.dbf.state.fl.us/licensing
Don Saxon
Director
dsaxon@dfs.state.fl.us

Georgia
Office of the Secretary of State
Division of Business Services and Regulation
Two Martin Luther King, Jr. Drive SE
802 West Tower
Atlanta, GA 30334
(404) 656-3920
(404) 651-6451 (Fax)
www.sos.state.ga.us/securities/
Wayne Howell
Director, Division of Securities
hwhowell@sos.state.ga.us
Hawaii
Department of Commerce & Consumer Affairs
Division of Business Registration
1010 Richards Street
2nd Floor
Honolulu, HI 96813
P.O. Box 40
Honolulu, HI 96810
(808) 586-2744
(808) 586-2733 (Fax)
http://www.hawaii.gov/dcca/breg-seu/
Ryan S. Ushijima
Commissioner of Securities
rushijim@dcca.state.hi.us
Idaho
Department of Finance
700 West State Street
2nd Floor
Boise, ID 83702
P.O. Box 83720

Boise, ID 83720-0031
(208) 332-8004
(208) 332-8099 (Fax)
www.state.id.us./finance/sec.htm

Marilyn T. Chastain
Securities Bureau Chief
mchastai@fin.state.id.us
Illinois
520 South Second Street
Suite 200 Lincoln Tower
Springfield, IL 62701
(217) 782-2256 (800) 628-7937
(217) 524-2172 (Fax)
http://www.cyberdriveillinois.com/
departments/securities/
Tanya Solov
Director of Securities
69 West Washington
12th Floor, Suite 1220
Chicago, IL 60602
(312) 793-3384
(312) 793-1202 (Fax)
tsolov@ilsos.net
Indiana
Securities Division
302 West Washington
Room E-111
Indianapolis, IN 46204
(317) 232-6681
(317) 233-3675 (Fax)
http://www.in.gov/sos/securities/index.html
James Joven
Securities Commissionner
jjoven@sos.state.in.us
Iowa
Insurance Division
Securities Bureau
340 E. Maple Street

Des Moines, IA 50319-0066
(515) 281-4441
(515) 281-3059 (Fax)
www.iid.state.ia.us/Division/Securities
Craig A. Goettsch
Superintendent of Securities
craig.goettsch@iid.state.ia.us
Kansas
Office of the Securities Commissioner
618 South Kansas Avenue
Topeka, KS 66603-3804
(785) 296-3307
(785) 296-6872 (Fax)
securities@securities.state.ks.us
http://www.securities.state.ks.us
Chris Biggs
Commissioner
chris.biggs@securities.state.ks.us
Kentucky
Department of Financial Institutions
1025 Capital Center Drive
Suite 200
Frankfort, KY 40601
(502) 573-3390 (800) 223-2579
(502) 573-8787 (Fax)
http://dfi.ky.gov/
Colleen Keefe
(502) 573-2182 (Fax)
colleen.keefe@mail.state.ky.us
Louisiana
Office of Financial Institutions
8660 United Plaza Blvd.
Second Floor
Baton Rouge, LA 70809-7024
(225) 925-4660

(225) 925-4524 (Fax)
www.ofi.state.la.us/securit.htm
Rhonda Reeves
Deputy Securities Commissioner
rreeves@ofi.state.la.us
Maine
Office of Securities
121 State House Station
Augusta, ME 04333
(207) 624-8551
(207) 624-8590 (Fax)
http://www.state.me.us/pfr/sec/sec_index.htm
Christine A. Bruenn
Securities Administrator
(207) 624-8555
christine.a.bruenn@state.me.us
Maryland
Office of the Attorney General
200 Saint Paul Place
Baltimore, MD 21202-2020
(410) 576-6360
(410) 576-6532 (Fax)
securities@oag.state.md.us
www.oag.state.md.us/
securities/index.htm
Melanie Senter Lubin

(410) 576-6365
mlubin@oag.state.md.us
Massachusetts
Securities Division
One Ashburton Place
Room 1701
Boston, MA 02108
(617) 727-3548

(617) 248-0177 (Fax)
www.state.ma.us/sec/sct/sctidx.htm
Matthew J. Nestor
First Deputy Secretary of the Commonwealth
(617) 727-7774
matthew.nestor@sec.state.ma.us
Michigan
Conduct Review & Securities Division
Office of Financial & Insurance Services
Department of Labor & Economic Growth
611 West Ottawa St, Third Floor
Lansing, MI 48933
P.O. Box 30701

Lansing, MI 48909-8201
(877)999-6442
(517)241-3953 (Fax)
ofis-sec-info@michigan.gov
www.michigan.gov/ofis
Linda A. Watters
Commissioner
Office of Financial & Insurance Services
Minnesota
Department of Commerce
85 East 7th Place
Suite 500
Saint Paul, MN 55101
(651) 296-4026
(651) 296-4328 (Fax)
commerce@state.mn.us
http://www.state.mn.us
Scott P. Borchert
Director, Enforcement Division
(651) 296-9431
scott.borchert@state.mn.us
Mississippi

Business Regulation & Enforcement Division
700 North Street
Jackson, MS 39202
P.O. Box 136

Jackson, MS 39205-0136
(601) 359-6371
(601) 359-2663 (Fax)
www.sos.state.ms.us
James O. Nelson, II
Assistant Secretary of State
Business Regulation & Securities Division
(601) 359-6747
jnelson@sos.state.ms.us
Missouri
600 West Main Street
Jefferson City, MO 65101
(573) 751-4136
(573) 526-3124 (Fax)
http://www.sos.mo.gov/securities/
Douglas M. Ommen
(573) 751-4704
ommend@sosmail.state.mo.us
Montana
Office of the State Auditor
840 Helena Avenue
Helena, MT 59601
P.O. Box 4009

Helena, MT 59604
(406) 444-2040
(406) 444-5558 (Fax)
http://www.state.mt.us
John Morrison
jmorrison@state.mt.us

Nebraska
Department of Banking & Finance
Bureau of Securities
1200 N Street
Suite 311
Lincoln, NE 68508
P.O. Box 95006

Lincoln, NE 68509-5006
(402) 471-3445
http://ww.ndbf.org/sec.htm
Jack E. Herstein
Assistant Director
jackh@bkg.state.ne.us
Nevada
Secretary of State
Securities Division
555 East Washington Avenue
5th Floor, Suite 5200
Las Vegas, NV 89101
(702) 486-2440
(702) 486-2452 (Fax)
sosmail@govmail.state.nv.us
www.sos.state.nv.us/securities/
Charles Moore
Securities Administrator
cemoore@govmail.state.nv.us
New Hampshire
Bureau of Securities Regulation
State House Annex
Suite 317A 3rd Floor
Concord, NH 03301
(603) 271-1463
(603) 271-7933 (Fax)
http://webster.state.nh.us/
sos/securities/
Mark Connolly
Deputy Secretary of State

Director of Securities Regulation
mconnolly@sos.state.nh.us
New Jersey
Department of Law & Public Safety
Bureau of Securities
153 Halsey Street
6th Floor
Newark, NJ 07102
P.O. Box 47029

Newark, NJ 07101
(973) 504-3600
(973) 504-3601 (Fax)
www.state.nj.us/lps/ca/bos.htm
Franklin L. Widmann
Chief
(973) 504-3610
(973) 504-3639 (Fax)
widmannf@smtp.lps.state.nj.us
New Mexico
Regulation & Licensing Department
Securities Division
2550 Cerrillos Road
Santa Fe, NM 87505
(505) 476-4580
(505) 984-0617 (Fax)
rldsd@state.nm.us
www.rld.state.nm.us/securities/
Bruce R. Kohl
bruce.kohl@state.nm.us
New York
Investor Protection & Securities Bureau
120 Broadway
23rd Floor
New York, NY 10271
(212) 416-8200
(212) 416-8816 (Fax)

www.oag.state.ny.us/investors
/investors.html
Gary Connor
First Deputy Bureau Chief
North Carolina
Department of the Secretary of State
Securities Division
P.O. Box 29622
Raleigh, NC 27626-0525
(919) 733-3924
(919) 821-0818 (Fax)
www.secretary.state.nc.us/sec/
David S. Massey
Deputy Securities Administrator
dmassey@mail.secstate.state.nc.us
North Dakota
600 East Boulevard
State Capitol, 5th Floor
Bismarck, ND 58505-0510
(701) 328-2910
(701) 255-3113 (Fax)
seccom@state.nd.us
www.state.nd.us/securities
Karen Tyler
Commissioner
(701) 328-4702
(701) 328-0125 (Fax)
ktyler@state.nd.us
Ohio
77 South High Street
22nd Floor
Columbus, OH 43215
(614) 644-7381
(614) 466-3316 (Fax)
www.securities.state.oh.us

Debbie Dye Joyce
Commissioner
(614) 644-7435
debbie.dyejoyce@com.state.oh.us
Oklahoma
Department of Securities
1st National Center, Suite 860
120 N. Robinson
Oklahoma City, OK 73102
(405) 280-7700
(405) 280-7742 (Fax)
general@securities.state.ok.us
www.securities.state.ok.us/
Irving Faught
Administrator
(405) 280-7706
ilf@securities.state.ok.us
Oregon
Department of Consumer & Business Services
Div. of Finance & Corp. Securities
350 Winter Street, NE
Room 410
Salem, OR 97301-3881
(503) 378-4387
(503) 947-7862 (Fax)
www.cbs.state.or.us/external/dfcs
Floyd Lanter
Division Administrator
floyd.g.lanter@state.or.us
Pennsylvania
Eastgate Office Building
1010 North 7th Street, 2nd Floor
Harrisburg, PA 17102-1410
(717) 787-8061
(717) 783-5122 (Fax)
www.psc.state.pa.us

Robert M. Lam
Chairman
(717) 787-6828
pscwebmaster@state.pa.us
Puerto Rico
Commission of Financial Institutions
1492 Ponce de Leon Avenue
Suite 600
San Juan, PR 00907
Fernández Juncos Station

P.O. Box 11855
San Juan, PR 00910-3855
(787) 723-3131
(787) 723-4225 (Fax)
http://www.cif.gov.pr/html/message.html
Felipe B. Cruz, Esq.

Assistant Commissioner
(787) 723-3131 ext. 2222
felipec@cif.gov.pr
Rhode Island
Department of Business Regulation
233 Richmond Street
Suite 232
Providence, RI 02903-4232
(401) 222-3048
(401) 222-5629 (Fax)
secdiv@dbr.state.ri.us
www.dbr.state.ri.us
Maria D'Alessandro Piccirilli

Associate Director & Superintendent of Securities
mpicciri@dbr.state.ri.us
South Carolina
Securities Division
Rembert C. Dennis Office Building
1000 Assembly Street
Columbia, SC 29201

P.O. Box 11549
Columbia, SC 29211-1549
(803) 734-4731
(803) 734-0032 (Fax)
agsecurities@ag.state.sc.us
www.scsecurities.com/
T. Stephen Lynch
Deputy Securities Commissioner
slynch@ag.state.sc.us
South Dakota
Dept. of Revenue and Regulation
445 E Capitol Avenue
Pierre, SD 57501-2000
(605) 773-4823
(605) 773-5953 (Fax)
securities@crpr1.state.sd.us
http://www.state.sd.us/drr2/reg/securities/index.htm
Gail Sheppick
Director
gail.sheppick@state.sd.us
Tennessee
Department of Commerce & Insurance
Securities Division
Davy Crockett Tower, Suite 680
500 James Robertson Parkway
Nashville, TN 37243-0575
(615) 741-2947
(615) 532-8375 (Fax)
securities.1@state.tn.us
http://www.state.tn.us/commerce/securities/index.html
Daphne D. Smith
Assistant Commissioner for Securities
Texas
State Securities Board
208 East 10th Street

5th Floor
Austin, TX 78701
P.O. Box 13167

Austin, TX 78711-3167
(512) 305-8300
(512) 305-8310 (Fax)
www.ssb.state.tx.us/
Denise Voigt Crawford

(512) 305-8306
(512) 305-8336 (Fax)
dcrawford@ssb.state.tx.us
Utah
Department of Commerce
160 East 300 South
2nd Floor
Salt Lake City, UT 84111
P.O. Box 146760

Salt Lake City, UT 84114-6760
(801) 530-6600
(801) 530-6980 (Fax)
security@utah.gov
www.securities.utah.gov
S. Anthony Taggart
Director
(801) 530-6606
ttaggart@utah.gov
Vermont
Department of Banking, Insurance, Securities & Health Care
Administration
89 Main Street
Drawer 20
Montpelier, VT 05620-3101
(802) 828-3420
(802) 828-2896 (Fax)
www.bishca.state.vt.us/
Tanya Durkee
Deputy Commissioner of Securities
tdurkee@bishca.state.vt.us
Virginia
State Corporation Commission
Division of Securities & Retail Franchising
1300 East Main Street
9th Floor
Richmond, VA 23219
P.O. Box 1197

Richmond, VA 23218
(804) 371-9051
(804) 371-9911 (Fax)
www.state.va.us/scc/division/
srf/webpages/homepage.htm
Ronald W. Thomas
Director
(804) 371-9006
rthomas@scc.state.va.us
Washington
Securities Division
150 Israel Road, SW
Tumwater, WA 98501
P.O. Box 9033

Olympia, WA 98507-9033
(360) 902-8760
(360) 902-0524 (Fax)
www.dfi.wa.gov/sd
Michael E. Stevenson
mstevenson@dfi.wa.gov
West Virginia
Office of the State Auditor
Securities Division
Building 1
Room W-100

Charleston, WV 25305-0230
(304) 558-2257(877) 982-9148
(304) 558-4211 (Fax)
securities@wvauditor.com
www.wvauditor.com/
Chester F. Thompson
Deputy Commissioner of Securities
chestert@wvauditor.com
Wisconsin
345 W. Washington Avenue
4th Floor
Madison, WI 53703
P.O. Box 1768

Madison, WI 53701-1768
(608) 266-1064
(608) 264-7979 (Fax)
www.wdfi.org/fi/securities/
Patricia D. Struck
Administrator
(608) 266-3432
patricia.struck@dfi.state.wi.us
Wyoming
Secretary of State
Securities Division
State Capitol, Room 109
200 W. 24th Street
Cheyenne, WY 82002-0020
(307) 777-7370
(307) 777-5339 (Fax)
securities@state.wy.us
http://soswy.state.wy.us/securiti/securiti.htm
Thomas Cowan
Division Director
(307) 777-5348
tcowan@state.wy.us

We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. 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.
XI.Critical Business Constituents, Banks, and Counter-Parties
A.Business constituents
We have contacted our critical business constituents (businesses with which we have an ongoing
commercial relationship in support of our operating activities, such as vendors providing us critical
services), and determined the extent to which we can continue our business relationship with them in
light of the internal or external SBD. We will quickly establish alternative arrangements if a business
constituent can no longer provide the needed goods or services when we need them because of a SBD
to them or our firm. Our major suppliers are listed on Exhibit B attached.
Rules: NASD Rule 3510(c) (7).
B.Banks
We have contacted our banks and lenders to determine if they can continue to provide the financing
that we will need in light of the internal or external SBD. The bank maintaining our operating account
is Westport National Bank, located at 1495 Post Road East, Westport CT 06880, Contact is Helen A.
Ranholm, telephone; 203-254-6304. The bank maintaining our Proprietary Account of Introducing
Brokers/Dealers (PAIB account) is the same as our Operating Account. If our banks and other lenders
are unable to provide the financing, we will seek alternative financing immediately from Chase Bank,
Main Street, Westport CT. Telephone 203-935-9935.].
Rules: NASD Rule 3510(c)(7).
C.Counter-Parties
We have contacted our critical counter-parties, such as institutional customers, to determine if we will
be able to carry out our transactions with them in light of the internal or external SBD. Where the

transactions cannot be completed, we will work with our clearing firm or contact those counter-parties
directly to make alternative arrangements to complete those transactions as soon as possible.
Rules: NASD Rules 3510(a) &(c)(7).
XII.Regulatory Reporting
Our firm is subject to regulation by the regulators listed above in X, part C. We now file reports with
our regulators using paper copies in the U.S. mail, and electronically using fax, e-mail, and the
Internet. In the event of an SBD, we will check with the SEC, NASD, and other regulators to
determine which means of filing are still available to us, and use the means closest in speed and form
(written or oral) to our previous filing method. In the event that we cannot contact our regulators, we
will continue to file required reports using the communication means available to us.
XIII.Disclosure of Business Continuity Plan
We provide in writing notification of our BCP disclosure statement to customers at account

opening. We also post the disclosure statement on our Web site and mail it to customers upon
request. Our disclosure statement is attached.
Rule: NASD Rule 3510(e).
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, on October 1st to modify it for any changes in our operations, structure, business, or location
or those of our clearing firm.
Rule: NASD Rule 3510(b).
XV.Senior Manager Approval

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its
obligations to customers in the event of an SBD.
Rule: NASD Rule 3510(d).
Signed: _______________________________
Title: _______________________________
Date: _______________________________
Exhibit
A
Rule# Record Person Responsible R

17a-4 Articles of Corporation Matthew Rochlin C
17a-3 Client Power of Attorney/client correspondence
Regulator Correspondence Marissa Santangelo
17a-4 Compliance Manual Marissa Santangelo C
12 Employment Applicaton for each Associated Person Dale Brown

U- 4 Dale Brown B
U-5 Dale Brown B
13 & 15 Fingerprint Cards Dale Brown B
14
16 List of Customers
Daily Summaries of Trading
Transaction Volume

17
18 Written Customer complaint Files Marissa Santangelo B
19 Compensation Records Richard Brown/ Acct. B
20 Compliance Procedures with Federal Requirements Marissa Santangelo B
21 Record of Which People Can Explain Records System in an Office Column D
22 Record listing each principal responsible for Establishig Marissa Santangelo M
Policies and Procedures to Ensure Compliance
17a-4 1
Checks, books, Bank Statements, Cancelled checks and cash
2 reconciliations Richard Brown/Acct. B
3 Bills relating to business Richard Brown/Acct. B
4
5 Trial Balances Richard Brown/Acct. B
6 Guarantees of accounts and all powers of attorney
Dale Brown/Matt
7 Written agreements entered into and related to business Rochlin B
8 Focus Richard Brown/Acct. S
Tax Returns Richard Brown/Acct. L
Vendor List Exhibit B
American Skandia
One Corporate Drive
Shelton, CT 06484
800-752-6342
Mutual Fund

American Stock Exchange
P.O. Box 11181A
New York, NY 10286
212-306-1000
Market Data
Anthem BCBS CT
P.O.Box 778
Lewiston, ME 04243
800-843-6096
Medical Insurance
Archipelago LLC
100 S. Wacker Drive
Suite 2012
Chicago, IL 60606
888-514-7284
Book Orders Electronic Trading
Arrowhead Solutions
109 Highland Ave
Needham, MA 02494
781-449-5077
Book Orders Electronic Trading
AT&T
P.O.Box 277019
Atlanta, GA 30384
800-235-7524
Phone Communication
BD Week
P.O.Box 90608
301-287-2223
Subscription

Broker Dealer Compliance
12 Parmenter Road
Londonderry, NH 03053
603-434-3594
Focus Reports
Bloomberg LP
P.O.Box 30244
Hartford, CT 06150
212-318-2500
Quotes
CDC, Compliance Data Center

P.O.Box 105835
Atlanta, GA 30348
775-588-0541
Client Verification Equifax
Citizen’s Bank
P.O. Box M
Providence, RI 02901
800-922-9999
Matt Personal
Chase Auto Financial

P.O.Box 15594
Wilmington, DE 19886
800-336-6675
Gay’s Car
CNA Insurance
P.O. Box 371952
Pittsburgh, PA 15250
203-966-2677
Workers Compensation and Car Insurance
Comscan
P.O.Box 14019
Newark, NJ 01798
212-747-0343
Syndicate Commission Filings
Custom Phone Inc

P.O.Box 4029
Norwalk, CT 06855
203-866-3494
Phone Repair
Chicago Stock Exchange

36295 Eagle Way
Chicago, IL 60678
800-227-4786
Services to Chicago Floor
Cingular Wireless
P.O. Box 6428
Carol Stream, IL 60197-6428
800-331-0500
Steve Marchese Phone
Cohen and Wolfe, PC

1115 Broad Street
P.O.Box 1821
Bridgeport, CT 06610
203-368-0211
Lawyers
Commissioner of Revenue
P.O.Box 2965
Hartford, CT 06104
860-947-1988
Taxes

Daily Graphs
P.O.Box 66919
Los Angeles, CA 90066
800-472-7479
Argosy
Darien Computer Consultants

429 Hoyt Street
Darien, CT 06820
203-249-5854
Computer Part and Inc
DHL Inc
P.O. Box 78016
Phoenix, CA 85062
800-225-5345
Mail
Dow Jones News Service

P.O. Box 30
Chicopee, MA 01021
609-520-5599
News Service
Direct TV (NYC)
P.O.Box 830032
Baltimore, MD 21283
800-531-5000
Cable TV Service
East Coast Office Systems

135 Pepe’s Farm Road
Milford, CT 06460
203-878-0008
203-878-3014
Copier Supplies
Fact Set Research Systems Inc

601 Merritt 7
Norwalk, CT 06851
203-810-1000
203-863-1501
Lion Shares Data
Gardella Courier Inc

P.O. Box 2299
Norwalk, CT 06852
203-846-2422
Courier Service
Global Computer Supplies

P.O. Box 5133
Dept 7777
Chicago, IL 60680
203-226-5343
Computer Supplies
Hartford Life Insurance

P.O. Box 1583
Hartford, CT 06144
800-523-2233
LTD Life Policy
Instinet Corporation
P.O Box 26097
New York, NY 10087
201-595-3295
INET NASDAQ Level 2
Internal Revenue Services

915 Lafayette Blvd.
Bridgeport, CT 06604
203-384-5818
IRS Taxes
International Securities Exchange (ISE)

60 Broad Street
New York, NY 10004
212-943-2400
Connection Fee
Iron Mountain Digital Archives

745 Atlantic Ave
Boston, MA 20111
617-357-6966
Email Storage
Larry Liberfarb
11 Vanderbilt Avenue
Suite 220
Norwood, MA 02062
781-255-8800
Accountant
Minolta Business Solution

P. O. Box 7247
Philadelphia, PA 19170
800-633-4594
Copier Lease Rental
NASDAQ Stock Market

P.O.Box 7777-W9940
Philadelphia, PA 19175-9075
800-855-3898
Connectivity
NYSE
11 Wall Street
New York, NY 10005
212-656-3000
Connectivity
NYFIX Inc
Stamford Harbor Park
333 Ludlow Street
Stamford, CT 06902
203-425-8000
Connectivity
OASYS
2967 Collection Center Drive
Chicago, IL 60693
617-856-2566
Direct Retrieval Fees
Option Price Reporting

P.O. Box 95718
Chicago, IL 60694
312-786-7195
8 Locations
Pershing LLC
One Pershing Plaza
Jersey City, NY 07399
201-413-2000
Clearing Services
Pitney Bowes Credit Corp

1 Elmcroft Road
Stamford, CT 06926
800-451-0412
Postage rental
Pitney Bowes Inc

P.O. Box 856390
Louisville, KY 40285
800-628-2721
Postage
Progressive
P.O. Box 13593
Philadelphia, PA 19101
800-999-8781
Gay’s Car Insurance
PayChex
11 Riverbend Drive South
P.O.Box 4816
Stamford, CT 06907
203-973-1050
Pay Roll Services
Reuters America LLC

P.O.Box 10410
Newark, NJ 07193
415-677-2576
Quotes
Revere Data LLC

220 Bush Street
Suite 660
San Francisco, CA 94104
415-782-0454
Quotes
Sprint
P.O. Box 1769
Newark NJ 07101
888-788-4727
Cell Phones
Sun Guard
7408 Collection Center Drive
Chicago, IL 60693
201-840-5611
Brokerage fees
SAVVIS Communications Corporation

P.O.Box 502880
St Louis, MO 63150
314-531-0728
Communications
SIA Compliance and Legal Division

120Broadway
35th Floor
New York, New York 10271
212-608-1500
Compliance and legal
SIPC
805 15th Street N.W.
Suite 800
202-371-8300
SIPC
Standard and Poor’s Corporation

P.O. Box 80-2542
Chicago, IL 60680
800-852-1641
Stock information
State of Connecticut Department of Revenue

P.O. Box 2967
Hartford, CT 06104
800-382-9463
Taxes

The Island ECN Inc
900 Plaza 10
Jersey City, NJ 07311
212-231-5000
Brokerage fees
Thomson Financial
P.O. Box 71601
Chicago, IL 60694
617-856-2146
Autex trading info system
Toronto Stock Exchange

The Exchange Tower
P.O.Box 421
2 First Canadian Place
Toronto, ON M5X 1J2
Canada
416-947-4670
888-873-8392
Exchange
Verizon Wireless
P.O. Box 489
Newark, NJ 07101
800-922-5469
Cell Phones
Westport National Bank

1495 Post Road East
Westport, CT 06880
203-254-6300
AP Bank
W B Mason and Co INC

355 Washington Ave
North Haven, CT 06473
888-926-1766
Office Supplies
Wall Street Journal

200 Burnett Road
P.O.Box 240
Chicopee, MA 01020
800-369-2834
Paper
Arrowhead Solutions’ production facility is operating out of a Co-location Site in Marlboro,

MA. As most colocation sites, we have redundant power and data feeds. In the event of
Production Server failures, we can have our Backup Server environment in Production within
the hour. We have our data lines with four major carries on two different backbones. Below is
a recent questionnaire of our Business Continuity Strategy and our Disaster Recovery Plan.
General Service Provider BCP/DR Questionnaire:
A Business Continuity Strategy

A1 In the event of a disaster or
significant disruption, does your Yes __X______ or No ________
organization have documented
plans for business continuity and IT
disaster recovery?
A If you answered, “Yes” to We have plans for both power and network
2 Question (A1), what type of failure outages for our colocation datacenter in
scenarios or outages do you plan for?
Marlboro. We have redundant power and
data feeds into our site and also have on site
generators to keep us operational.
A If you answered, “Yes” to Our Power Outage plan and our network
3 Question (A1), what duration of time is
assumed for each type of failure scenario or outage plan are designed for 100% uptime. It
outage you plan for? is designed for any duration of time.
A4 What types of business functions Support our main business applications.

do you consider critical?
A5 If you answered “Yes” to Question

(A1), does the plan establish Yes ____X____ or No ________
critical business functions with
recovery priorities?
A5 If you answered “Yes” to Question

(A5), what is the expected recovery 0 – 4 hours __X___
time for your critical business 4 – 8 hours _____
functions? Within one day _____
1 – 2 days _____
More than 2 days _____
Other (please specify) _____
N/A _____

A7 If you answered, “Yes” to Question
(A1), does the plan account for Yes ____X____ or No ________
interdependencies both internal
and external to your organization?

(A1), does the plan cover some, Some
most, or all locations from which Most X
you provide your services? All
Other (please specify)
N/A

(A1), what percentage of “business 1 – 10% _____
as usual” servicing capability is the 11 – 20% _____
plan designed to address? 21 – 30% _____
31 – 50% _____
51 – 75% _____
76 – 99% _____
100% _____
A Do you have a dedicated

10 team of professionals focused on Yes ___X_____ or No ________
business continuity and/or IT disaster
recovery?
A If you answered “No” to

11 Question (A10), do you use an external Yes ________ or No ________
BCP/DR service provider to handle your
planning needs?
A12 Do you use an external BCP/DR

service provider to handle your Yes ________ or No ____X____
hardware recovery needs?

service provider to handle your Yes ________ or No ____X____
software recovery needs?

service provider to handle your Yes ___X_____ or No ________
telecom recovery needs?

service provider to handle your Yes ____X____ or No ________
work area recovery needs?
A16 Is your main IT facility or

data center Yes ________ or No ___X_____
located in the same
building or office complex occupied by
your main business or operations staff?
A17 Please provide an illustration or ____________________________________

schematic of how your ____________________________________
organization’s primary, secondary, _________________(Please attach an
and/or tertiary servicing centers are additional sheet if you need___ _____more
setup to provide redundant room to answer this question)_________
services to customers.
B Crisis Communication
B1 Do you have a documented crisis

management process within your Yes ___X_____ or No ________
organization?

B2 If you answered “Yes” to Question
(B1), does this process cover Yes ___X_____ or No ________
internal and external
communications during a crisis
event?
B3 How do you notify your clients of Phone, e-mail, fax, web site.
an outage?
B4 Do you provide your customers Yes ___X_____ or No ________
with detailed contact information in
the event of an outage or
emergency?
B5 Please describe how you notify Our team is first notified by e-mail, then by
your team of an incident and direct phone or pager. Depending on the incident,
them through the recovery. the person who is
on call addresses the incident. All team
members are trained for all types of incidents
that may occur.
C Back Up Facilities
C Does your organization

1 have an alternate site location for data Yes ________ or No ___X_____
center recovery purposes?
C2 If you answered, “Yes” to

Question (C1), what is the approx. ____________________________________
distance between your production ______ (Please specify # and miles/kms, city
(primary) site and alternate blocks, etc.)
(secondary) site for data center
recovery purposes?

Does your organization
have an alternate site location for work Yes ___X_____ or No ________
C area recovery purposes?
3
C4 If you answered “Yes” to

Question (C3), what is the approx. 10 Miles
distance between your production ____________________________________
(primary) site and alternate ______ (Please specify # and miles/kms, city
(secondary) site for work area blocks, etc.)
recovery purposes?
C5 Do you use an external BCP/DR

service provider for your data Yes ________ or No ___X_____
center recovery needs?
C6 Do you use an external BCP/DR

service provider for your work area Yes ___ _____ or No ___X_____
recovery needs?
C7 If you answered “Yes” to Question

(C6), is your contract with your Yes ________ or No ___X_____
BCP/DR service provider honored
on a first-come/first-served basis?
C8 What recovery strategy does your

organization use for mainframe Active/Active _______
systems? Active/Back-up _______
Vendor Supplied _______
Other _______
N/A ____X___
C9 What type of recovery strategy Active/Active _______

does your organization use for Active/Back-up _______
distributed systems? Vendor Supplied _______
Other _______
N/A ____X___

C1 Is the processing capacity of your
0 back-up facility equal to that of Yes ________ or No ____X____
your primary facility?
C11 If you answered “No” to Question 1 – 10% _____

(C10), what is the capacity ratio of 11 – 20% _____
your back up to your primary 21 – 30% _____
facility? 31 – 50% _____
51 – 75% _____
76 – 99% _____
100% _____
N/A __X___
C1 Is it feasible to run your primary

2 “data center” or technology center Yes ________ or No ____X____
from your back-up facility for an
extended period? (e.g. at least one
month)
C1 Is it feasible to run your primary

3 “people” or work area from your Yes ________ or No ___X_____
back-up facility for an extended
period? (e.g. at least one month)
D Testing
D1 If you answered “Yes” to Question

(A1), is the plan periodically Yes ___X_____ or No ________
tested?
D2 If you answered "Yes" to Question

(D1), how frequently is the plan Annually __X___
tested? Semi-annually _____
Other (please specify)
_________________________

D3 Do you have BCP test dates
scheduled over the next 12-18 Yes ___X_____ or No ________
months?
D4 If you answered "Yes" to Question _12/04______
(D3), please list those dates (for _______
industry planning purposes) _______
_______
_______

(D1), do you involve IT staff, IT staff only __X___
business unit or operations staff or Business Unit or Operations Staff only _____
both in your internal BCP/DR Both IT and Business Unit or Operations
tests? Staff______

(D1), do you also involve Yes ___X_____ or No ________
customers in your external
BCP/DR tests?
D7 If you answered “Yes” to Question 1 – 10% __X___

(D6), what is the percentage of 11 – 20% _____
customer participation? 21 – 30% _____
31 – 50% _____
51 – 75% _____
76 – 99% _____
100% _____
N/A _____

(D1), do internal or external Yes ___X_____ or No ________
auditors review your BCP/DR
tests?

D9 If you answered “Yes” to Question Applications __X____
(D1) what components of your Middleware __X___
systems and infrastructure are Databases __X____
tested? Data networks __X____
(internal and external)
Voice networks __X____
(internal and external)
Desktop __X____
Facilities __X____
Voice equipment __X____
Pershing ®
A BNYSecurities Group Co.

Solutions from the Bank of NewYork
Contingency Planning
Introducing Broker - Dealer Summary

Version 3.0
March 2004

FOR PERSHING INTRODUCING BROKER/DEALER USE ONLY.
NOT FOR DISTRIBUTION TO THIRD PARTIES.
CONFIDENTIAL

Table of Contents
Nutmeg Securities Ltd Business Continuity Planning.........................................................1
I. Emergency Contact Persons.............................................................................................3
II. Firm Policy .......................................................................................................................4
A. Significant Business Disruptions (SBDs).........................................................................................4
B. Approval and Execution Authority...................................................................................................4
C. Plan Location and Access ................................................................................................................4
III. Business Description.......................................................................................................4
IV. Office Locations...............................................................................................................5
V. Alternative Physical Location(s) of Employees................................................................9
VI. Customers’ Access to Funds and Securities..................................................................9
VII. Data Back-Up and Recovery (Hard Copy and Electronic)...........................................10
VIII. Financial and Operational Assessments ....................................................................10
A. Operational Risk.............................................................................................................................10
B. Financial and Credit Risk................................................................................................................11
IX. Mission Critical Systems...............................................................................................11
A. Our Firm’s Mission Critical Systems.............................................................................................12
1. Order Taking................................................................................................................................12
2. Order Entry .................................................................................................................................13
3. Order Execution...........................................................................................................................13
4. Other Services Currently Provided to Customers.......................................................................13
B. Mission Critical Systems Provided by Our Clearing Firm.............................................................14
X. Alternate Communications Between the Firm and Customers, Employees, and Regulators
............................................................................................................................................14
A. Customers.......................................................................................................................................14
XI. Critical Business Constituents, Banks, and Counter-Parties .......................................37
A. Business constituents......................................................................................................................37
B. Banks..............................................................................................................................................37
C. Counter-Parties...............................................................................................................................37
XII. Regulatory Reporting...................................................................................................38
XIII. Disclosure of Business Continuity Plan......................................................................38
XIV. Updates and Annual Review.......................................................................................38
XV. Senior Manager Approval ..........................................................................................38
XVI. Purpose.......................................................................................................................63
XVII. Mission ......................................................................................................................63
XVIII. Planning Structure and Basic Assumptions..............................................................63
XIX. Event Management Structure.....................................................................................64
B. Incident Management Team (IMT).................................................................................................65
Coordinate with essential business personnel, for instance managers and business continuity
coordinators.....................................................................................................................................65
C. Response Teams..............................................................................................................................66
D. Business Units................................................................................................................................66
2. Line Managers.............................................................................................................................66
4. Business Continuity Team Captains............................................................................................66
6. IMT Liaison.................................................................................................................................66
XX. Communications with Customers................................................................................66
B. Outbound Communications............................................................................................................66
1. Account Managers and Customer Service Associates.................................................................66
C. Inbound Communications...............................................................................................................66
2. Problem Notification...................................................................................................................66
XXI. Security Policies.........................................................................................................68
B. Data Security ................................................................................................................................68
C. Physical Security Access................................................................................................................68
XXII. Business Continuity ..................................................................................................69
1. Business Continuity Plans and Risk Assessments.......................................................................69
2. Recovery Sites.............................................................................................................................69
3. Testing.........................................................................................................................................69
XXIII. Disaster Recovery ...................................................................................................70
1. Mainframe...................................................................................................................................70
2. Distributed Systems.....................................................................................................................70
3. Network.......................................................................................................................................70
4. Testing.........................................................................................................................................71

XVI.Purpose
The purpose of this document is to provide our customers with an overview of
our business continuity and disaster recovery plans, including a high-level
definition of the policies and procedures that we will employ in the event of a
business interruption.
XVII.Mission
Pershing's mission for contingency planning is to ensure the continuous, reliable
delivery of service to Pershing's customers while maintaining regulatory compliance.
XVIII.Planning Structure and Basic Assumptions

The basic planning assumptions for the contingency plan are the following:
1. Pershing assumes that not more than one of its critical facilities will be affected at one time. All
other facilities will remain accessible and operational.
2. Pershing assumes that its critical infrastructure (such as electric, water, heat, ventilation, air
conditioning, etc.) will remain operational as long as the facility is accessible. This assumption is
based on the amount of effort that Pershing has undertaken to fortify these facilities (for instance,
Pershing maintains redundant generators, chillers, etc.).
 If an event causes the evacuation of our operations center in Hudson County, New Jersey,
Pershing will declare a business continuity event, and activate the business continuity plan.
This will result in a four-hour processing outage to enable switching of data and voice
communications and relocation of associates to our data center in Morris County, New Jersey.
 If an event causes the closing of our data center in Morris County, New Jersey, Pershing will
declare a disaster recovery event, and activate the Disaster Recovery plan. This will result in a
four-hour outage while our mainframe processing is transferred to our Hudson County back-up
site.
3. Pershing assumes that all customer sites and facilities (such as electricity, water, heat,
ventilation, air conditioning, etc.) are accessible and operational.
4. Pershing assumes that it will have adequate staffing available during the event.
63
XIX.Event Management Structure
Pershing has established an event management structure to respond effectively to business
emergencies. This structure will be activated during any business continuity or disaster recovery event.
At the center of the event management structure is Pershing’s Command and Control Center, which is
occupied by the Incident Management Team (IMT).
The following diagram illustrates Pershing’s event management structure:
Executive Commanders
IMT Coordinators
Technology Business Unit Operations Customer / External Corporate Support

Management Representation Services
Tech. Management Business Unit Management Cust. Representation Corporate Services
Disaster Recovery Corporate Comm. Business Continuity
Info Security Legal & Compliance
Audit
Chenai
Branch Offices
Response Business
Teams Units
Voice/Data/
Infrastructure Application
Desktop Response Business Unit Business Unit Business Unit
Response Team Response Team
Team
IMT Liaison IMT Liaison IMT Liaison Line Manager Line Manager Line Manager
BCP Coordinator BCP Coordinator BCP Coordinator
IMT Liaison IMT Liaison IMT Liaison
A.
64
B.Incident Management Team (IMT)
IMT members and their alternates are proxy representatives whose extensive experience
at Pershing allows them to understand the implications of individual business unit issues
while maintaining a corporate perspective. Their responsibilities include the following:
 Ensure departments comply with requests for status or directives from IMT.
 Obtain the operational status of the departments or customer groups they represent.
 Assess incident and determine the firm-level response, including invocation of
business continuity or disaster recovery plans.
 Ensure responses are implemented correctly.
 Coordinate with essential business personnel, for instance managers
and business continuity coordinators.
1.
Executive Commander
 Focal point for decision-making and execution of strategies for the IMT.
 Acts as a liaison to the Executive Committee
 Coordinates activities at the corporate and business unit levels
IMT Coordinator
 Coordinates the flow of information into the IMT, structures meetings, etc.
Technology
 Ensure appropriate information is collected and presented to IMT
 Coordinate allocation of PTG resources
 Ensure that IMT directives are implemented
 Act as liaison with technical vendors/service providers
Business Unit Management

 Ensure that appropriate information collected about incident and wellness status of
business unit
 Make decisions on contingency actions
 Ensure contingency actions undertaken are implemented.
Customer / External Representation

 Represent the customer’s interest in the decision making process
 Ensure that communications and/or messages from IMT are delivered consistently
 Compose, review and manage all communications with external entities
(correspondents, media, etc.)
 Manage “hotline” and other internal communications
Corporate Support Services

 Provide information on impact of incident
65
 Support and facilitate firm’s contingency actions
 Ensure contingency actions undertaken are compliant with laws, rules and regulations
and provide sufficient controls.
 Act as liaison with regulatory agencies
C.Response Teams
The Pershing Technology Group has dedicated teams of technologists to

advise and respond to events, as directed by the IMT. These teams are organized by area
of expertise and relevant skill sets.
D.Business Units
Each of Pershing’s business units has dedicated teams of associates to

perform the specific functions identified below:
1.
2.Line Managers
The line managers are responsible for enacting their business continuity
plans, as instructed by the Incident Commander.
3.
4.Business Continuity Team Captains
The business continuity team captains support the line managers with their
knowledge of the business unit’s contingency plans and assist in the activation of those
plans.
5.
6.IMT Liaison
The IMT liaison is responsible for communicating the status of the
business units to the IMT and providing the line managers with current IMT decisions.
XX.Communications with Customers

A.
B.Outbound Communications
1.Account Managers and Customer Service Associates

Pershing Account Managers and Customer Service Associates will contact
customers with information or instructions.
C.Inbound Communications
1.
2.Problem Notification
It is the expectation that customers continue to use existing
communication channels with Pershing.
66
Customers who wish to notify Pershing of problems will continue to call
Pershing’s Technology Customer Service at (201) 413-2001, as they would normally.
3.
67
XXI.Security Policies
A.
B.Data Security
Pershing produces and stores paper and/or magnetic copies of all relevant access data and
programs so that in the event that the security access files or programs are destroyed or
corrupted due to an event, they can be quickly reconstructed in accordance with
Securities and Exchange Commission regulations.
C.Physical Security Access
If there is a security system failure at Pershing’s facilities due to an event, we will

implement the following guidelines:
 Only Pershing associates and authorized vendor support personnel will be allowed
access. All access will be monitored. ALL associates will be required to show
Security a valid Pershing Identification Card and to sign in with Lobby Security at the
start of the business day and each time thereafter upon entering the facility
 Access to restricted areas (such as the data center) will only be authorized after an
access validity verification by Security. This access will be granted only after
verification by Security of access validity. Security will maintain an up-to-date listing
of all associates with current card or sign-in authorization to access these areas
 Any access required by associates, vendors, and consultants must be approved by the
senior management of the restricted areas involved
 Vendors that must be on-site in order to perform any required maintenance or repairs
must be accompanied by a Pershing associate
68
XXII.Business Continuity
Business continuity at Pershing is defined as the orderly return to normal business

operations after events that have affected Pershing Plaza. Integral to the success of
Pershing’s business continuity program is our ability to relocate associates and resume
business functions at our Morris County and alternate Hudson County facilities.
1.Business Continuity Plans and Risk Assessments

Pershing maintains over 50 written business resumption plans that cover all aspects of
the resumption of business processes for each department. These plans are updated semi-
annually with consultants from Sungard Planning Solutions and their PreCovery
software package. Current copies of these plans are maintained in several off-site
locations. Risk assessments are also performed every time the BC plans are updated. The
impact of any changes in Pershing’s processes, products, or business environment are
evaluated, which may result in modifications to the configuration of the recovery sites as
described below.
2.Recovery Sites
Pershing maintains two business resumption sites for personnel: The Morris County
facility provides for the relocation of over 700 associates to resume processing
operations, and the alternate facility in Hudson County provide for the relocation of 250
traders. Each operations desktop or trading position used in business continuity is loaded
with all software, as well as all telecommunication requirements needed for the associate
to continue in their role. Centralized fax and wire printer rooms are maintained where all
communications to Pershing are centrally located and controlled.
Business continuity “partitions” on the hard drives of the recovery workstations are used
in business continuity to hold client server, market data, and desktop applications
separately from the day-to-day uses of the machine.
Pershing also maintains a telephone rollover scheme whereby inbound Pershing Plaza
calls and faxes are routed to Morris County or the alternate facility in Hudson County by
the local telephone company.
3.Testing
Each seat in both facilities is tested at least twice a year. These Saturday tests involve
700 associates at Morris County and 250 traders at the alternate facility in Hudson
County logging into the business continuity machines and testing accessibility to all
applications.
69
XXIII.Disaster Recovery
The focus of disaster recovery is the re-establishment of the data processing

infrastructure such as technology platforms, applications, network infrastructure, and
systems access. It also includes the recovery of the technology personnel responsible for
data center operations; system software and operating environments; and network,
communications, and applications support. These are multi-platform-interconnected
systems that support the business of Pershing and our customers. Services include the
planning, coordination, and execution of periodic disaster recovery exercises; the
development and maintenance of Pershing's disaster recovery plans; and implementation
of new and leading-edge technology solutions. Plans have been developed and are
maintained for the mainframe, distributed systems, and network environments.
Additional services we provide to our customers include assistance in the design and
testing of their disaster recovery capabilities with respect to Pershing.
1.Mainframe
Pershing has implemented a state-of-the-art internal mainframe disaster recovery
capability based on IBM Geographically Dispersed Parallel Sysplex/eXtended Remote
Copy (GDPS/XRC). GDPS/XRC provides replication of data between the primary
Morris County data center and the secondary data center in Hudson County. XRC is the
disk-mirroring component and GDPS is the automation component. The mirrored data
center automatically copies more than 20 terabytes (7,300 direct access storage device
volumes) of information - equivalent to the text content of 20 million 400-page books.
The mainframe systems are restarted and operational in less than four hours with less
than five minutes data loss. Pershing is the world’s largest mirrored data center using
IBM mainframes and storage devices.
2.Distributed Systems
Front-end client/server, web, and interactive voice recognition (IVR)
systems are engineered to provide load balancing between the data centers in Morris
County, New Jersey and Hudson County, New Jersey. In the event of an outage in
Hudson County, the Morris County servers will assume the entire workload.
Conversely, if there is an outage in Morris County, the Hudson County servers will
assume the entire workload. In both cases, the transition requires little or no manual
intervention.
For back-end processing systems, Pershing has implemented an EMC

Symmertrix Remote Data Facility (SRDF) disk-mirroring technology solution to
augment the current Tivoli Storage Manager based (restore from backup) internal
capability
3.Network
Internal redundancy is inherent within the network design with
production network traffic supported from two geographically dispersed facilities,
70
Morris County and Hudson County. Both facilities are designed to support the network
in the event of a disaster at either location.
4.Testing
The disaster recovery capabilities are aggressively tested on a quarterly
basis. After each test, a written critique is prepared documenting any problems
encountered during the test or areas where improvement may be necessary. If you
would like to participate in one of our tests please contact your Account or Relationship
Manager. Client participation is welcomed, but due to the complexity involved it is
limited to a first come/first serve basis and no more than 10 clients per test.
71

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Nutmeg Securities Ltd Business Continuity Planning

Nutmeg Securities Ltd

proprietary and confidential 2

I.Emergency Contact Persons

Rule: NASD Rule 3520.

proprietary and confidential 3

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding

A.Significant Business Disruptions (SBDs)

B.Approval and Execution Authority

C.Plan Location and Access

Our clearing firm is:

TEL: 800-443-4342 or 201-413-4017

Office Location #1 Head Office - Nutmeg Securities Ltd

Office Location #2 - Nutmeg Securities Ltd

Office Location #3- Nutmeg Securities Ltd

Office Location #4 – Future Benefits

proprietary and confidential 5

Office Location #5 – Heritage Benefits Consultants

Office Location #6 – Spectrum Financial Strategies, Inc.

Office Location #7 – Advisors One, LLC

Office location #8 - Nutmeg Securities Ltd

Office Location # 9 - Nutmeg Securities Ltd

Office Location #10 - Nutmeg Securities Ltd

. Office Location # 11– Nutmeg Securities Ltd

Office Location # 12 – Freedom Financial

Office Location # 13 – Metro Pension Analysts Ltd.

Office Location #14 – Advanced Benefit Strategies

proprietary and confidential 7

Office Location #16 – Nutmeg Securities Ltd

Office Location # 17- Nutmeg Securities Ltd

Office Location #18 - Nutmeg Securities Ltd

Office Location # 19 - Nutmeg Securities Ltd

Office Location # 20- Nutmeg Securities Ltd

proprietary and confidential 8

Office Location # 21– Nutmeg Securities Ltd

V.Alternative Physical Location(s) of Employees

Rule: NASD Rule 3510(c)(6).

VI. Customers’ Access to Funds and Securities

VII.Data Back-Up and Recovery (Hard Copy and Electronic)

Rule: NASD Rule 3510(c) (1).

VIII.Financial and Operational Assessments

proprietary and confidential 10

Rules: NASD Rules 3510(c)(3) & (f)(2).

B.Financial and Credit Risk

Rules: NASD Rules 3510(c)(3), (c)(8) & (f)(2).

IX.Mission Critical Systems

MASLOW : Electronic trading system

A.Our Firm’s Mission Critical Systems

4.Other Services Currently Provided to Customers

B.Mission Critical Systems Provided by Our Clearing Firm

Rules: NASD Rules 3510(c) & (f)(1).

X.Alternate Communications Between the Firm and Customers, Employees, and

Rule: NASD Rule 3510(c)(4).

proprietary and confidential 14

Caller Call Recipients

Marissa Santangelo Christina Alvarado

Cathy Mayberry Shaneka Shuler

Dale Brown Hans Kummerfeld

Caller Call Recipients

Tom Hiten Kevin Grenham

Bryan Bogen Vincent Falade

Ed Perry John Aitken