Bruce A. Lefavi Securities, Inc.

Business Continuity Plan

I. Emergency Contact Persons

Our firm’s three emergency contact persons are: Bruce A. Lefavi: H: 801-883-0511,

W: 801-486-9000, Cell: 801-633-3833, email: lefavi@lefavi.com; Sherrie Bakelar W:

801 486-9000 H: 801 969-9210, email: starconspirator@gmail.com,

sbakelar@lefavi.com; and Deborah Holmes: W: 801-486-9000, Cell: 904-874-8971,

email: dholmes@lefavi.com. These names will be updated in the event of a material

change, and our Executive Representative will review them regularly.

II. Firm Policy

Bruce A. Lefavi Securities, Inc.’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 firm.

B. Approval and Execution Authority

Bruce A. Lefavi, a registered principal, is responsible for approving the plan and for

conducting the required annual review. Bruce A. Lefavi has the authority to execute this

C. Plan Location and Access

Our firm will maintain copies of its BCP plan, the periodic reviews, and the changes that

have been made to it for inspection. An electronic copy of our plan is located in the

file/folder name: W:\Compliance\BCP. A hard copy can be found under Business

Continuity Plan in our regulatory/compliance file with the rest of the related folders (our

executed copy) and in our written supervisory procedures.

Bruce A Lefavi Securities, Inc. BCP

III. Business Description

Our firm conducts business primarily in mutual funds and variable annuities, but also to a

lesser extent, equity and fixed income, as well as direct participation programs. 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. Most 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. In cases for which our clearing broker does not offer certain products, such as

variable annuities and direct participation products, we invest directly with the offering

company. The offering company in this case takes custody of the customer funds and

invests in, holds, record keeps, reports on the customers’ assets as well as facilitates any

transactions necessary, such as issuing funds or securities to the customer. In some cases,

especially for smaller clients, we will also purchase mutual fund shares directly from the

offering mutual fund company as opposed to through our clearing broker. This is

typically done when it is easier and less costly to the client to transact business in this

manner. Our firm services only retail customers.

Our clearing firm is: Sterne, Agee & Leach, Inc.(SALI), 980 North Federal Hwy, Ste

308, Boca Raton, FL 33432, 800-264-4863, dferguson@sterneagee.com and our contact

person at that clearing firm is Dennis Ferguson, 800-264-4863,

dferguson@sterneagee.com or Don Exner, 800-264-4863, dexner@sterneagee.com. Our

clearing firm has also given us the following alternative contact in the event it cannot be

reached: Eric Warner or Sue at the Clearing Liaison Desk: 800-778-6257,

ewarner@salfin.com , internet access: www.salclearing.com; www.sterneagee.com

The following is a summary of the important relevant facts to us regarding our clearing

firm’s BCP that they provided to us:

In the event of an interruption of service at SALI, you will receive a blast email from our

office indicating the nature of the interruption, an estimate of the duration of the

interruption and alternate means for you to accomplish the desired service at issue.

Subsequent to the remedy of the interruption, you will receive a blast email notification of

the return to “normal business operations” interrupted by the disruption.

1. SALI may be contacted, in an emergency, direct at 800-264-4863, 888-678-3763

or 800-778-6257. Our BCP provides for switching all direct telephone numbers

to a location (if necessary) where staff will be available to conduct the processing

of transactions.

2. Customers may identify contact information at www.salclearing.com

3. Customers will have ability to access funds in their account by requesting a wire

transfer or issuance of a check on an uninterrupted basis.

4. Best practice is to have your customers use the check writing features for funds

5. SALI has redundant connectivity to all exchanges, clearing agents and banks from

alternate location cites.

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Bruce A Lefavi Securities, Inc. BCP

6. Depending on the severity of the interruption, while order entry capability will be

uninterrupted, reports of execution may be slowed or delayed due to nature of

interruption (i.e. exchange outage, executing agent outage, ILX or Beta

interruption.)

7. SALI uses Beta Systems for its processing. Beta has dual locations, which

“mirror” all processing live 24/7. Consequently, any interruption should be

minimal equaling only the time to reconnect to alternate location via back up data

lines. Your ILX/Beta internet connection known as “thin client” enables you to

direct connect to Beta without being affected by a SALI location outage.

8. It is unlikely that SALI will suffer a disaster of such magnitude that it will

mandate that SALI discontinue operations. FINRA requires that each member

firm discuss this circumstance. Your plan as well must address the possibility of

business discontinuance. Your customers, via the SALI BCP, will have access to

account assets as described in the attached.

IV. Office Locations

Bruce A. Lefavi Securities, Inc. has only one office (main office) described below.

A. Main Office Location

Our Main Office Location is at 2323 Foothill Dr., Suite 100, Salt Lake City, UT 84109.

Its main telephone number is 801-486-9000. Our employees may travel to that office by

means of foot, car, bicycle, or bus. We engage in all OSJ recordkeeping including our

electronic systems and backups, all back office functions, order taking and entry at this

V. Alternative Physical Location(s) of Employees

In the event of an SBD, staff will work from home using internet access, if available and

personal phones. At this location we have remote access to our computer systems,

telephone access, and if needed access to offsite backup of all electronic records (client

database, client records, office records, accounting records, etc.)

VI. Customers’ Access to Funds and Securities

Our firm does not maintain custody of customers’ funds or securities, which are

maintained at our clearing firm, Sterne, Agee & Leach or directly with a particular

mutual fund company or variable annuity company for our application way accounts. 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 or other

custodian 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 the custodian

of their account. For any SALI accounts they can contact SALI’s Clearing Liaison Desk

directly at 800-778-6257. For any other accounts held by another custodian, they can

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Bruce A Lefavi Securities, Inc. BCP

contact the custodian by calling the number listed on their statement. 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.

SIPC contact Info:

 www.sipc.org

 Tel: (202)371-8300

 Fax: (202)371-6728

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

the main office: 2323 Foothill Dr., Suite 100, Salt Lake City, UT 84109. Bruce A.

Lefavi, President, 801-486-9000, is responsible for the maintenance of these books and

records. Our firm maintains the following document types and forms that are not

transmitted to our clearing firm: New client documents (Client Fact Finder, Client

Account Card), additional client documents necessary for new accounts (trust agreement,

articles of incorporation, retirement plan documents, etc.), tax returns, financial plans,

and client disclosure forms (mutual fund disclosure, annuity disclosure, MLP disclosure,

Switch Replacement Forms, etc.). Electronically, we keep client information (name,

address, phone, ss#, birth date, etc), client notes, investment summaries and records, and

financial plans. Our Client Relationship Management (CRM) database is stored offsite,

administered by Ebix.com. If there are any problems, we can contact Michael Shaw at

626-585-3505 ext. 7241; email: Michael.Shaw@ebix.com, or his colleague Chad Snyder

at 626-585-3505 ext 7236. Technical support can also be reached at 626-585-3515. Data

in the CRM is backed up on a daily basis.

The firm backs up its electronic records daily by recording all relevant data on our main

server to a digital backup tape, and keeps a copy offsite. Contact: Michelle Gallagher,

1788 E. 4620 S. Salt Lake City UT, 84117.

In the event of an internal or external SBD that causes the loss of our paper records, we

will recover what we can from our clearing broker, other custodians, and from any

electronic copies we may have. 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.

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Bruce A Lefavi Securities, Inc. BCP

VIII. Financial and Operational Assessments

Bruce A. Lefavi and any other relevant senior management will identify any significant

changes in its operational, financial, and credit risk exposures in the event of an SBD

during the annual compliance meeting.

A. Operational Risk

In the event of an SBD, we will immediately identify what means will permit us to

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 internet, telephone, alternative location telephone, company cell

phones, telephone voice mail, and e-mail. In addition, we will retrieve our key activity

records as described in the section above, Data Back-Up and Recovery (Hard Copy and

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, other custodians of our clients

funds, 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 scaling down operations to a minimum

in order to operate as long as possible to resolve problem and contact SIPC if necessary.

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: Smart Office CRM – Our

database of client information and secondary source of investment records; eCustody –

Our internet-based access to our clearing broker from which we can enter orders and

access client records and investment information; clearing broker website – gives us

access to client requests such as check requests, wire requests, change of address, etc. all

these functions may be done via phone or email as well. The clearing broker website also

gives us access to all of our activity reports such as trade blotters, commission activity

reports, and exception reports. Telephone system – All clearing broker functions such as

order entry and delivery of client funds may be done via phone with the clearing broker.

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Bruce A Lefavi Securities, Inc. BCP

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. Our clearing firm or other custodians provide,

through contract, the 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.

Our clearing firm contract provides that our clearing firm will maintain a business

continuity plan and the capacity to execute that plan. Our clearing firm represents that it

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 its plan, which is attached to

our BCP. In the event our clearing firm executes its plan, it represents that it will notify

us of such execution and provide 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

Our clearing firm represents that it backs up our records at a remote site. Our clearing

firm represents that it operates a back-up operating facility in a geographically separate

area. Our clearing firm has also confirmed the effectiveness of its back-up arrangements

to recover from a wide scale disruption by testing frequently.

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 time and resumption objectives: recovery time period of

within the hour; and resumption time of within minutes, virtually continuous.

A. Our Firm’s Mission Critical Systems

1. Order Taking

Currently, our firm receives orders from customers via telephone and 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, and in addition, as

communications permit, we will inform our customers when communications become

available to tell them what alternatives they have to send their orders to us. Customers

will be informed of alternatives by email, website postings, and regular mail (if time

permits). If necessary, we will advise our customers to place orders directly with our

clearing firm at the Clearing Liaison Desk: 800-778-6257.

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Bruce A Lefavi Securities, Inc. BCP

2. Order Entry

Currently, our firm enters orders by electronically entering them directly on our clearing

brokers system (eCustody internet based system) and sending them to our clearing firm

electronically through the same system. Alternatively, we place customer orders by

calling our clearing broker’s trading desk directly. We have contacted our clearing

broker and were told that, under its BCP, we can expect continual service.

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 email, phone, and internet. 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.

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.

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 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. 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 by 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.

The person to invoke use of the call tree is: Bruce A. Lefavi. See Attachment C, for the

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Bruce A Lefavi Securities, Inc. BCP

Rule: FINRA 4370.

C. Regulators

We are currently members of the following SROs: FINRA. 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: Client Database Smart Office, EZ-Data, 918 East Green Street,

Pasadena, California 91106, (626) 585-3515. Internet Service, Windstream – PAETEC,

2855 E Cottonwood Pkwy, Salt Lake City, UT, 84121; phone: 1-866-445-5882.

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: Chase Bank, Foothill Village Branch, 1440 S.

Foothill Dr. Ste 100, Salt Lake City, UT 84108, (801) 481-5821 (Contact Dane Jensen).

Our Proprietary Account of Introducing Brokers/Dealers (PAIB account) is held by our

clearing firm, Sterne, Agee & Leach, Inc., 813 Shades Creek Parkway, Suite 100B,

Birmingham AL 35209, 800-778-6257.

C. Counter-Parties

We have contacted our critical counter-parties, such as other broker-dealers or

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

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Bruce A Lefavi Securities, Inc. BCP

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.

XII. Regulatory Reporting

Our firm is subject to regulation by: SEC, FINRA, Utah State Securities Department. 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, FINRA, 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. SEC:

(801) 524-5796, e-mail: saltlake@sec.gov. FINRA: (301) 590-6500. Utah State Securities

Dept: (801) 530-6600.

XIII. Disclosure of Business Continuity Plan

We provide in writing a BCP disclosure statement to customers at account

opening. We also mail it to customers upon request, and send an offer letter to all

clients annually. Our disclosure statement is attached

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, during our annual compliance meeting, to modify it for any

changes in our operations, structure, business, or location or those of our clearing firm.

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.

Signed:    Lefavi Signature

Title: President

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Bruce A Lefavi Securities, Inc. BCP

ATTACHMENT A

STERNE AGEE CLEARING

BUSINESS CONTINUITY AND CONTINGENCY PLANS

(“BCP”)

AN EXECUTIVE SUMMARY

Sterne Agee & Leach, Inc. (“SALI”) is required to establish and maintain a BCP

per FINRA RULE 4370.

SALI is a subsidiary broker dealer of Sterne Agee & Leach Group (“SALG”). As

such, SALI BCP is incorporated into a global plan along with other operating

affiliates under SALG. Elements of the global plan are referenced below and may

be viewed on the Sterne Agee Clearing website under www.salclearing.com.

Sterne Agee Capital Markets doing business as Sterne Agee Clearing provides

solutions to various business continuity exigencies that may impact our

correspondent broker dealers who introduce customers on a fully disclosed

The following are the ten (10) key elements, as mandated by FINRA RULE 4370

Rule 3510, of the SALG BCP with references to appropriate citations contained

in various affiliate division individual plans.

1. Books and records back-up and recovery – SALI information technology

department has a standing procedure of full back up of operating data that

is cycled offsite each five (5) business days. Information Technology has

alternate connectivity channels to Beta as well as all third party

data/service providers.

2. Identification of all mission critical systems and back-up for such

systems – SALI management information systems through it’s “Disaster

Recovery Guidelines” document has identified as mission critical those

systems including Beta, ILX and connectivity to all exchanges and clearing

facilities. Through the use of alternate sites and back-up dial capability

from portable computer equipment, MIS is prepared to provide either

uninterrupted or minimally interrupted service for the operations and

clearing functions.

3. Financial and Operational risk assessments: SALI has long standing

relationships with AmSouth Bank , UMB as well as Bank of New York

which include the ability to provide on an uninterrupted basis those

financial resources (and in some cases physical facilities usage) for SALI

to continue operations and clearing functions under any set of exigencies.

4. Alternative communications between customers and the firm:

customers of introducing broker dealers rely on existing communication

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Bruce A Lefavi Securities, Inc. BCP

methods with their respective broker dealer to obtain account information

and perform order entry

functions as well as request transfer of funds. Introducing broker dealers

in turn have communication capabilities via internet and telephony with

SALI. Ultimately, customers of introducing broker dealers have the

capability to communicate directly with SALI and Sterne Agee Clearing

through internet connectivity and telephony. Contact information and

directions are shown on Sterne Agee Clearing website

www.salclearing.com as well as elsewhere in this document.

5. Alternate communications between the firm and its employees – SALI

has established as part of its BCP a calling tree utilizing either land line,

internet or cell phone capabilities between and among all of its operations

and clearing personnel.

6. Alternate physical location of employees – SALI through its BCP has

arranged for alternate locations for the conduct of the operations and

clearing function in the event of a business interruption. These sites

include existing SALI facilities in Atlanta, Birmingham and Boca Raton.

7. Critical business constituent, bank and counter-party impact – SALI as a

member of DTCC, and other executing and processing agents has on

hand copies of BCP’s for each of the critical business constituents.

Frequent testing of communications alternatives, site locations and

processing systems is conducted between SALI and its critical business

constituents on a routine basis.

8. Regulatory reporting – SALI has as its’ Designated Examining Authority

the New York Stock Exchange. All regulatory reporting including FOCUS,

Reserve Calculations and routine compliance and operations reporting

data is prepared at a location separate from the operations unit. In the

event of a business interruption designated personnel can relocate

between the present operations and headquarters locations, both of which

contain communication and data resources in order to produce and deliver

requisite regulatory reports.

9. Communications with regulators – each operating affiliate broker dealer

under SALG has on file with regulators the name and contact information

of key SALI personnel in both Compliance and Operations areas. Internet

and cell phone capabilities enable SALI appropriate personnel to

communicate on an uninterrupted basis from any location.

10. How the member or member organization will assure customer prompt

access to their funds and securities in the event the member or member

organization determines it is unable to continue its business – in the event

of an business interruption wherein SALI operations is caused to relocate

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Bruce A Lefavi Securities, Inc. BCP

to an alternate site, customers of introducing broker dealers have a

uninterrupted access to their funds by identifying balances via internet

access, contacting their introducing broker dealer or telephoning the SALI

operations center alternate location (contact numbers below). Customers

may withdraw funds from their accounts by using

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Bruce A Lefavi Securities, Inc. BCP

the check writing feature of all money market instruments offered through SALI

or by contacting SALI direct or through their introducing broker dealer

requesting that a wire or check be sent to their bank or address of record. In the

event that a disaster of such magnitude mandates the discontinuance of

operations, SALI would perform an orderly discontinuance of business under its

present BCP, properly notify regulatory authorities including Securities Investor

Protection Corporation (visit www.sipc.org). Executive Officers of SALG would

coordinate this procedure. Customers of introducing broker dealers would have

access to their account funds by methods described above. Subsequent to a

declaration of discontinuance of business operations customers of introducing

broker dealers could effect a transfer of account assets via a Automated

Customer Account Transfer request to another clearing member firm.

In summary, SALI through the use of state of the art technology anticipates a virtual

continuous access by customers to information regarding their accounts including

positions, order entry and removal of funds. Customers may call or visit one of the

sites below for access to Sterne Agee & Leach, Inc. during a declared business

Sterne Agee & Leach Contact:

Internet: www.salclearing.com; www.sterneagee.com

Operations 888-678-3763

Clearing Help Desk: 800-264-4863

Clearing Liaison Desk: 800-778-6257

Corporate Administration: 800-240-1438

Sterne Agee & Leach, Inc. membership number DTC 0750; CRD # 791

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Bruce A Lefavi Securities, Inc. BCP

ATTACHMENT B

BRUCE A. LEFAVI SECURITIES, INC.

BUSINESS CONTINUITY PLAN (“BCP”)

DISCLOSURE FORM

Bruce A. Lefavi Securities, Inc. (“BLS”) is required to establish and maintain a BCP

and update on an annual basis. The following are some of the key elements:

1. Books and records back-up and recovery – BLS information technology

department has a standing procedure of full back up of operating data that is

cycled offsite each business day.

2. Identification of all mission critical systems and back-up for such systems –

BLS has identified all mission critical systems and through the use of an alternate

site with remote connectivity to our computer systems BLS is prepared to provide

either uninterrupted or minimally interrupted service for its operations.

3. Alternative communications between customers and the firm: In the event that

clients of BLS are unable to contact our company via phone due to a severe

business disruption, BLS will post all available alternative phone numbers to the

website: www.lefavi.com. In addition, clients of BLS may always contact the

custodian of their funds directly for any matter, including obtaining account

information, placing trades and accessing their funds. The contact information

can be found on the account statement from the specific custodian firm. For any

accounts held by Sterne, Agee & Leach (SAL), you may contact SAL directly at

the Clearing Liaison Desk: 800-778-6257. In the event that a disaster of such

magnitude mandates the discontinuance of operations, BLS would perform an

orderly discontinuance of business under its present BCP, and properly notify

regulatory authorities including Securities Investor Protection Corporation (visit

www.sipc.org). Executive Officers of BLS would coordinate this procedure.

Clients of BLS would have access to their account funds by methods described

above. Subsequent to a declaration of discontinuance of business operations

clients could effect a transfer of account assets to another financial firm.

4. Alternate physical location of employees – BLS through its BCP has arranged

for an alternate location for the conduct of the operations in the event of a

business interruption. In addition, BLS has established as part of its BCP a

calling tree utilizing either land line, internet or cell phone capabilities between

and among all of its personnel. If the business interruption is severe enough to

affect our office or business district for longer then a business day, we will

continue to do business through our alternate site. If the disruption is city-wide or

larger, we will resume business as soon as we are reasonably able and may

invoke a more remote alternative site. However, clients in the meantime should

have continuous and immediate access to their funds as outlined in section 3

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Bruce A Lefavi Securities, Inc. BCP

In summary, BLS through the use of its BCP policy outlined above anticipates a virtual

continuous access by customers to information regarding their accounts including

positions, order entry and removal of funds.

15

Bruce A Lefavi Securities, Inc. BCP

ATTACHMENT C

CALL TREE

The person to invoke use of the call tree is: Bruce A. Lefavi

Caller Call Recipients

Bruce A. Lefavi Deserae Hulce

Deserae Hulce Sherrie Bakelar, Deborah Holmes, Chris Light

Sherrie Bakelar Sam Fowers, Cathy Ramos, Michelle Gallagher

Deborah Holmes T. J. Walk, Chase Flint, Stephen Pace, Trevor

T. J. Walk John Jaicks

Trevor Knudtson JD Slatter

Stephen Pace Ben Marshall

Shane Schut

Knudtson, Andrew Jose