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First Empire Asset Management, Inc.

Business Continuity Plan

First Empire Securities, Inc., LPC Services, Inc., Balance Sheet Management and Consulting Services, Inc., First Empire CD Management, Inc., First Empire Asset Management, Inc., and its affiliates, parent companies and subsidiaries have developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us

If after a significant business disruption you cannot contact us as you usually do at 631-979-0097, 800-645-5424, or 888-620-5736 you should call our alternative number 800-551-2971 or go to our web site at www.1empire.com. If you cannot access us through either of those means, you should contact your custodian directly. If Pershing is your custodian, you may contact them at 201-413-3635 or 213-624-6100 ext. 500 for instructions on how it may provide prompt access to funds, securities, account information and/or to enter orders or accept your account instructions.

Our Business Continuity Plan

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

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

Our clearing firm, Pershing LLC, backs up our broker-dealer records in a geographically separate area. 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 firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four hours. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our firm, 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 also 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 expect to recover and resume business within 24 to 48 hours. 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 within 24 to 48 hours. 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.1empire.com or our customer emergency number, 800-551-2971 how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.

For more information

If you have questions about our business continuity planning, or to have a copy of this document mailed to you, please contact us at 631-979-0097.

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*First Empire Asset Management, Inc. is not a member of FINRA or SIPC.

 

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