Business Continuance Plan

In the event a of a local catastrophe due to severe weather or terrorist attack which disables normal business activities in the region (White Plains or Westchester), business operations would be temporarily relocated to an off-site temporary office established for the expressed purpose of business continuance. We have arranged for the use of three separate locations within New York State to operate should it become necessary. It is the intention of the firm to remain in business and have our alternative services fully functional with a matter of days. Basic communications and network data infrastructures would be implemented as necessary and arrangements have been made with varying vendors to provide us with the required tools and expertise to accomplish this. This may include but not be limited to areas in northern and southern New York State.

If a statewide emergency should occur, whereby normal business operations are interrupted in New York State, Hamilton Cavanaugh & Associates, Inc. would, if conditions permitted, establish temporary business facilities in New Jersey for the sole purpose of keeping communication lines open between the firm, its customers and related entities. We have arranged for the use of three separate locations within New Jersey in which to operate on a temporary basis until such time as alternative space can be arranged. If for any unforeseen reason this can not be facilitated, Hamilton Cavanaugh & Associates, Inc. will establish a messaging system to notify its customers and related entities of the seriousness of the business interruption and status of restructuring efforts on an ongoing basis.

These following excerpts from our business continuance plan are subject to modification by Hamilton Cavanaugh & Associates, Inc. at any time. Should a modification occur, an updated summary will be promptly posted on our web site and customers may alternatively obtain updated summaries by requesting a written copy by U.S. mail. The following summarizes our plans.

1. 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 through their individual investment houses.
2. 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 could 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 the investment houses that are responsible for your assets.
3. Hamilton Cavanaugh & Associates, Inc. currently operates out of one location located at 661 North Broadway, North White Plains, NY 10603.
4. In the event of a localized crisis, an alternative physical location located in Westchester County has been arranged. In the event the alternative physical location can not be established or utilized, employees will be notified as to the status of their requirement for their physical presence at an alternative work location.
5. Hamilton Cavanaugh & Associates, Inc. does not hold in street name or any other form securities purchased or held for our client / customers. Maintenance and updating of client / customer account information is the sole responsibility of the associated financial product provider. Clients / customers will be referred to the appropriate financial product provider for account data information and transactional inquiries and requests.
6. Our firm maintains its primary hard copy books and records and its electronic records at 661 N. Broadway, White Plains, NY 10603. Our internal and external servers are backed up nightly to a secure off-site facility and a “full system backup” occurs on a weekly basis. In the event any of the server(s) should be rendered unavailable, services hosted on the aforementioned server(s) would become unavailable as well until such time a replacement server can be configured and information restored utilizing the “last known good” system backup from the previous day. The processes to accomplish this and the technical expertise are already in place should an SBD occur and it is anticipated that no more than 2-3 days would elapse before we would be fully functional.

   Hard copy items entering the office are filtered and then scanned into our internal document imaging software which resides on its own dedicated server. The Document server is backed up using the same convention as our other existing servers and data is recovered or restored using similar methodologies.

7. Alternative communications with our customer / clients will be established via a temporary phone system set in place at our predetermined alternative physical location. Direct phone lines (including faxes) to our existing office will be forwarded to and handled by our alternative physical location. Communications will also be done via our Web site and direct contact.
8. Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those who provide us services. In addition, our firm will review the BCP annually, on or before June 30th, to modify it for any changes in our operations, structure, business, or location or those who provide us recovery services.
   In the event Hamilton Cavanaugh & Associates, Inc.’s main office structure should become inaccessible or inoperable due to unforeseen circumstances whereby interrupting normal business operations, this plan would become effective to ensure business continuance. In the case of this particular localized business interruption, an off-site temporary office would be established and basic communications and network data infrastructure implemented as necessary.

Sincerely,

John J. Hamilton