TJM maintains a Business Continuity Plan (“BCP”) to address and guide our response and recovery from a Significant Business Disruption (“SBD”). Copies of this Summary Disclosure Statement shall be provided to clients at the time they open their accounts. The BCP is subject to modification, and an updated summary will be distributed to our clients when modified. Alternatively, clients may obtain a summary of the BCP via mail, by requesting a copy.

TJM’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.

Customers’ Access to Funds and Securities

Our Firm does not maintain custody of customers’ funds or securities, which are maintained by the clearing members. Customers will need to contact the clearing member with customer orders or instructions. The Firm will make this information available to customers through its disclosure policy.

Alternate Communications

We now communicate with our customers using the telephone, e-mail, fax, U.S. mail, and in person visits at our Firm or at the other’s location. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

Alternative Physical Location(s) of Employees

In the event of an SBD, our staff will operate remotely from their homes.