BUSINESS CONTINUITY PLAN

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.

COMMUNICATION WITH OUR EMPLOYEES IN THE EVENT OF A DISRUPTION

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. Our firm does not maintain custody of customers’ funds or securities. In the event of an SBD, either external or internal, 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 Web site, telephone voice mail, secure e-mail and postal mail service.

No plan is effective without proper documentation. Therefore, Abner, Herrman & Brock LLC has developed and maintains a business continuity plan. This plan includes mobilization procedures, notification guidelines, call trees and other pertinent information for the business as well as plans for crisis management and executive management personnel to ensure proper coordination of command and control activities in the event of an emergency.

This plan is subject to modification, an updated summary will be promptly posted on our website and customers may alternatively obtain updated summaries by requesting a written copy by mail.