In accordance with regulatory requirements, Oscar Gruss & Son Incorporated has developed a plan in the event of a “Significant Business Disruption” (SBD). Under those regulations we are obligated to make available to our clients a summary of such plan. Please understand that the plan contains confidential details and proprietary information and therefore cannot be distributed outside the firm. We will review the plan annually and it may be amended at any time.

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 DBS relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

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 – particularity telecomunications – 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 diruption. Our clearing firm has the following SBD recovery time and resumption objectives: recovery time period of 1 to 24 hours. The Firm’s recovery time for systems related matters is estimated at 20 to 30 minutes. If it is deemed necessary to move personnel we anticipate a recovery time, which takes into consideration travel, to be an hour and one-half.