Business Continuity

SMIA has developed a Business Continuity Plan on how we will respond to events that signifcantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be fexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan. The specifcs of our business plan are subject to modifcation. Updated plans will be promptly posted on our website at www.smartmoney.co.

Contacting Us : If after a signifcant business disruption you cannot contact us as you usually do at 415-800-4678 or [email protected], you should visit our website, www.smartmoney.co. If you cannot access us through either of those means, you should contact our broker-dealer frm ChoiceTrade at 787-680-0085 or www.choicetrade.com or our clearing frm Velox at 949-352-4694 or www.velox-global.com to obtain access to your funds or securities.

Our Business Continuity Plan : We plan to quickly recover and resume business operations after a signifcant business disruption and respond by safeguarding our employees and property, making a fnancial and operational assessment, protecting the frm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our frm to resume operations as quickly as possible, given the scope and severity of the signifcant business disruption.

Our business continuity plan addresses data backup and recovery; all mission critical systems; fnancial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counterparty impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing frm backs up our important records at a remotely independent site. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing frm that its objective is to restore its own operations and be able to complete existing transactions and accept requests for funds and securities as soon as possible. Your requests for funds and securities could be delayed during this period.

Varying Disruptions : Signifcant business disruptions can vary in their scope, such as only our frm, a single building housing our frm, the business district where our frm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In the event of a disruption to either our building or area, we plan to continue in business, transfer operations to our clearing frm if necessary, and notify you through our web site www.choicetrade.com how to contact us. If the signifcant business disruption is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at [email protected]

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