Disclosure

Our Business Continuity Plan – Tobin & Company has developed a business continuity plan on how we will respond to events which could 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.

We plan to recover and resume business operations after a significant business disruption as promptly as practicable and to safeguard our employees and property, make a financial and operational assessment, protect the firm’s books and records and allow our clients 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 back up 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 counterparty impact; and regulatory reporting if we are unable to continue our business.

Contacting us – if after a significant business disruption you cannot contact us as you usually do by either email or at the telephone number of our office, you should call 704.905.4006 for further information.

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 another location when needed. In a disruption affecting our business district, city or region, we will transfer our operations to a location outside of the affected area and recover and resume business operations. In either situation, our goal is to recover and resume business operations as promptly as practicable in the circumstances. For more information – if you have questions about our business continuity planning, you can contact us at 704.334.2772 and request to speak to Justine Tobin.

Our business continuity plan and this disclosure are intended to comply with the rules promulgated by the Financial Industry Regulatory Authority, Inc. This plan is subject to modification. If modified, an updated summary will be promptly posted on our web site. Clients may obtain updated summaries by requesting a written copy by mail. The information contained in this disclosure is provided for informational purposes only.