Employee Safety
Regular evacuation drills and emergency preparedness meetings, led by trained security professionals are held by our facilities to ensure employee safety in the unlikely event of an emergency.

Destruction of the Firm's Principal Place of Business
In event that the principal place of business is destroyed or damaged to a point where it cannot be utilized, the Contact Manager will contact each employee and provide instructions for reporting to work. Allen C. Ewing & Co. has two primary locations in Jacksonville, FL and Charlotte, NC. These separate sites provide backup for most critical functions.

Notification to the Proper Authorities
After an emergency has been declared, the Disaster Team Leader will notify the proper regulatory authorities and the Designated NASD Examiner of the nature of the emergency, the temporary location of the firm and any other information as required by law. Additionally, the Contact Manager will notify the local public utilities, telephone company, post office and any other vendor as deemed necessary.

Regulatory Reporting
Regardless of the extent or scope of destruction, this plan is designed to ensure that Allen C. Ewing & Co. can continue to meet all regulatory requirements. ACE will be able to continue all regulatory reporting through our secondary location or alternate work site.

Equipment / Hardware
The Contact Manager will maintain a list of all equipment, hardware and software, used by the firm. The list shall contain the item, the serial number, the manufacturers and serial/registration number. The Contact Manager will also notify the firm's insurance company of any damage.

A secure back-up system has been created on our server, which will enable us to keep a weekly back-up of all records on the server in an offsite location in case of a disaster.

Mission Critical Systems
Mission critical systems include server, FBSI and Streetscape access, of which all can be retrieved via a secure online VPN connection from any offsite location.

Client Information and Client Trading Records
Hard copies and electronic original client agreements, contracts, profiles, and other documentation related to each client as well as trading records, brokerage statements and confirmations are maintained at the principal place of business for the appropriate time that is required by law. After such time the documentation may be moved offsite to a secure facility where both client and firm confidentially can be assured.

Copies of pertinent client information can be requested from our clearing firm National Financial Services, LLC as needed.

Semi-Annually, the a designated principal will review these Business Continuity plans pertaining to our clients records to assure that these records will be adequately maintained in the event of a disaster or emergency.

Communication with Clients

Upon the declaration of an emergency, where normal lines of communication are no longer available, all personnel will attempt to communicate with their clients via any means available. Customer information can be accessed offsite at all times via National Financial, LLC's online connection, Streetscape. Each registered representative should also maintain a list of their current clients, which includes all known contact numbers (home, work, cell phone, pager number and e-mail addresses). If the registered representative is unable to contact their clients, they shall report the situation to the firm's principal. Upon notification, the firm's principal will attempt to contact the client. A log will be kept of each attempt and each client contacted.

Notifications will include the length of outage, instructions for contacting ACE and National Financial Services, LLC and any other pertinent information.

When contacting the local telephone service, a message will be set up to redirect all clients to the appropriate alternative office.

Preparedness of Vendors and Custodian
Allen C. Ewing & Co. will request copies from all critical vendors and custodians of their Business Continuity Plan or a confirmation from such vendors or custodian that a plan exists, is current and has been tested. A log will be maintained of all vendors and custodians and their emergency contact numbers. Such list shall be reviewed annually.

Vendors and custodian preparedness will be discussed amongst the principals of the firm in the event that they are not satisfied that any such vendor or custodian is adequately prepared for an emergency. The vendor or custodian should also be contacted to discuss any concerns relative to the plan that he/she may have. Such conversations will be documented and kept in a vendor and custodian file.

Operational, Financial and Credit Risk Assessment
Due to the nature and size of our business, there will be minimal impact if one of our offices is affected by an unlikely disaster. Operations can resume in our secondary office location, customer assets are securely held by our introducing firm, National Financial Services, LLC and there is appropriate insurance coverage to assist ACE in the reestablishment of its office.

Emergency Contact Information
Allen C. Ewing & Co. will report to the NASD, via such electronic or other means as the NASD may require, prescribed emergency contact information. The emergency contact information will include the designation of two emergency contact persons, which will be a part of senior management and a registered principal.

Allen C. Ewing & Co. will promptly update all emergency contact information, via such electronic or other means as the NASD may require, in the event of material change. Allen C. Ewing & Co. will also update its emergency contact information, including the designation of two emergency contact persons, within 17 business days after the end of each calendar quarter to ensure the information's accuracy. The Executive Representative, or his or her designee, which designation must be in writing, must conduct such review and update.

Notification to Clients of the Firms Business Continuity Policies
Allen C. Ewing & Co. will notify each client at account opening, and annually of the disaster preparedness plans. The notification will contain contact numbers (such as telephone numbers, Internet address, pager numbers, etc.) that may be used by the client to reach someone at Ewing in case of an emergency.

If key personnel or Allen C. Ewing & Co. are unable to carry out their usual duties, the notification will contain the telephone number and a contact person at the custodian firm that will assist the client and assure prompt access to their securities and funds in the event of an emergency.

Emergency Contact Information
Jacksonville Office (904) 354-5573
Charlotte Office (704) 332-2032
Email: tjones@allenewing.com
National Financial Services, LLC (617) 563-5977