Business Continuity Program 
 
Purpose

This document provides a general overview of the Business Continuity Program (BCP) for Wall Street Access. A BCP is a program we design to help ensure that we can continue to do business even if we experience an unplanned business interruption such as a loss of a utility service, a building evacuation, or a catastrophic event.

Recovery Strategies

Our technology systems are located in two different facilities. This design ensures that if one of our locations suffers a disruption in service, all business critical functions can be restarted at the alternate site. As a result, should there be an event that prevents us from having access to a building, whether because of a disruption to the building, a business district, or a city, we can rely on the systems in the other location so that both ourselves and our customers can continue to conduct business within a short interval.

Our BCP is designed to take into consideration a localized disruption, such as a disruption confined to the space occupied by Wall Street Access, as well as a disruption to a business area or regional location where Wall Street Access is located. In the event of a business interruption of any kind, we have plans and teams in place to address the immediate response to the incident, the management of the situation from the time of the incident until the matter is resolved, and a business unit and information technology recovery plan. For each of these teams, we have plans to address incidents when one of our worksites (including the technology housed at that worksite) becomes unavailable for some reason, as well as when a technology or other service provider stops working for some reason. Whatever the event, our BCP is designed to enable us to be back in operation within 24 hours or less.

In creating our BCP, we do assume that the alternative location is available, that we have sufficient personnel, and that external organizations such as government agencies and market systems are operational. If any of these assumptions is in error, our business could be disrupted until these matters are resolved.

Plan Testing and Updating

At a minimum our BCP is reviewed, updated, and tested annually. Additionally, the BCP will be updated on an as-needed basis as business processes, technology, or staff change. We will continue to post general and updated information about our BCP promptly on our Web site. Alternatively, you may obtain an updated BCP plan summary by requesting a written copy by mail. Send your request to Wall Street Access Attn: Compliance Dept., 17 Battery Place, New York, NY 10004.