Business Continuity plan

In the event of a Significant Business Disruption (SBD) Wolf A. Popper, Inc. has developed a contingency plan. The following is a summary of this plan:

Our plan anticipates two kinds of SBD's, internal and external. Internal SBD's affect only our firm's ability to communicate and do business, such as a fire in our building. External SBD's 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 (Apex Clearing Corp.). As a part of this plan we have received continuity plans from each of our affiliates.

Should our current location (99 Wall Street, 6th Floor New York, NY 10005) become non-operational due to an event such as a flood or a fire, our firm will resume business as usual at an alternate physical location. The recovery time for such an event is estimated at 30 minutes or as long as it takes for a Principal to reach the alternate facility and initiate the necessary computer systems. In this case clients will be alerted to the move and given new contact information.

In the event of a smaller scale external SBD, such as one that affects the City of New York or our Region, we will contact Apex Clearing and let them know that we are unable to conduct business at our location and that our clients will be contacting them directly. Clients will be notified of the situation and provided with Apex Clearing Corp.'s direct contact information. In this instance, clients will be able to place trades directly with Apex Clearing Corp. and will have access to their funds/accounts directly through Apex Clearing Corp.. We estimate recovery time for an event of this magnitude to be only minutes. If the external SBD is larger in scale and affects the operation of the securities markets, we will notify our clients and help facilitate the withdrawal of any funds that may be available to them if they desire to do so. Any withdrawal must comply with Wolf A. Popper, Inc.'s current policies and procedures. We will notify our clients once the securities markets resume operations.

A paper copy of Wolf A. Popper, Inc.'s business continuity plan may be obtained by submitting a written request to the Compliance Department. This plan is subject to modification and updated plans will be promptly posted to the website.