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registered investment adviser
independent investment advice since 1988

Continuity Plan For Responding To Events That Significantly Disrupt Our Business

FLEIXIBILITY: The timing and impact of disasters and disruptions are unpredictable and therefore the response must be flexible.

CONTACTING US: Telephone numbers: Toll free, 877-571-9826; Toll numbers, 928-899-5395, 602-412-3361; Fax: 928-999-1995. Email: stu@sethornco.com and info@sethornco.com. If you are unable to contact us you should contact Pershing Advisor Solutions LLC.

CONTACTING PERSHING ADVISOR SOLUTIONS LLC: Pershing LLC – Headquarters One Pershing Plaza, Jersey City, New Jersey 07399 (800) 445-4467. It is suggested that Clients request the operator to connect them with PAS group and than ask the PAS representative for instructions on how Pershing may provide them with prompt access to funds and securities, enter orders, and process other trade-related cash and security transfer transactions. Clients may also contact Pershing at www.pershingadvisorsolutions. com and then use the contact page to provide the information requested.

RECOVERY: The plan objectives are to quickly recover and resume business operations as quickly as possible after a significant business disruption and respond to disruptions by safeguarding employees and property, making a financial and operational assessment, protecting the firm’s books and records, and helping our clients to continue transacting business as early as possible following disruptions.

ISSUES ADDRESSED: The plan addresses: data back up and recovery, restoration of critical systems, resident financial and operational assessments, protecting the firms books and records, alternative communications with Clients while assisting our Clients with the conduct of their business, alternative communications with employees and regulators, alternative physical location of employees, establishing critical contacts with suppliers, banks, counter-parties, regulatory reporting and helping our Clients work with Pershing Advisor Solutions LLC to access their funds and securities if we are unable to continue our business.

PERSHING ADVISOR SOLUTIONS LLC: PAS and their parent company Pershing LLC backs up our Clients important records in a geographically separate area. Although every emergency poses unique problems based upon external factors, our clearing firm has advised up that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments immediately. Pershing Advisor Solutions LLC Your orders and requests for funds and securities could be delayed during this period.

DISRUPTIONS VARY: Significant business disruptions can vary in their scope, such as only our firms, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and will work diligently to recover and resume business as quickly as possible. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business as quickly as possible. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.sethornco.com or via a recorded message on our main business phone number. If you require additional assistance, you can call our clearing firm, Pershing Advisor Solutions, at (800) 445-4467. If the significant business disruption is so severe that it prevents us from remaining in business, we will work with our Clients with the assistance of Pershing Advisor Solutions to achieve prompt access to their funds and securities.

ADDITIONAL INFORMATION AND QUESTIONS: Questions, requests for additional information, and suggestions for plan improvement are encouraged. Please use the methods of contact listed or our Website “Contact” page.

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