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Batavia: 585.344.1850

Business Continuity Disclosure Policy

Brighton Securities Business Continuity Disclosure

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.

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.

Approval and Execution Authority

Jai Ramachandran, Chief Executive Officer, is a registered principal.  He is responsible for approving the firm’s business continuity plan and ensuring the required annual review is conducted.  Mr. Ramachandran has the authority to execute this plan.

Customers’ Access to Funds and Securities

Our firm does not maintain custody of customers’ funds or securities; these are accessed through our clearing firm, Wells Fargo Clearing Services, LLC.  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 on their behalf.  If our Web access is available, our firm will post pertinent information on our Web site so that customers may access their funds and securities by contacting our Operations Department.  The firm will make this information available to customers through its disclosure policy.

Our clearing firm regularly backs up its important information in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our clearing firm has a thorough Business Continuation Plan in place and has assured us that its objective is to restore its own operations in order to complete existing transactions and accept new transactions and payments in a timely manner.

As a client of Brighton Securities, we recognize you may need access to your account to sell a position or request a check before we can re-establish telephone or other communication services with you. During this time, our clearing firm will assist you with sell or liquidation orders and provide check disbursements, as required. If you cannot contact our firm by any means, please call 877-496-3223 for assistance.

We provide advice and direction that comes not just from market expertise and experience, but from listening to you, our client. We place you at the center of your financial plan.

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