Business Continuity Plan

The firm maintains a business continuity plan (“Plan”). Consistent with regulatory requirements, the firm provides this disclosure statement to our clients which summarizes the Plan. The Plan is reviewed annually and may be updated at any time.

The Plan is designed to be activated in the event of a significant business disruption. The Plan attempts to continue critical operations if an event were to occur that would impact the firm’s business location or systems. The Plan anticipates a variety of significant business disruptions and the actions the firm would take in the event of a building, city‐wide or regional incident.

The Plan provides that, upon the occurrence of a significant disruption, the firm will immediately perform an initial assessment of the severity of the event. 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 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.

In designing our Plan, we do assume that our pre-designated alternative sites are accessible, and that the market system is functioning and available.

If, in the event of significant business disruption, you cannot contact us as you usually do, please contact us by email at or contact us through our website at