BUSINESS CONTINUITY PLAN TRIPOINT GLOBAL EQUITIES, LLC Last Updated: October 2016

Table of Contents INTRODUCTION ........................................................................................................................................... 4  GENERAL COMPLIANCE ANALYSIS ........................................................................................................ 5  FINRA RULE 4370 .................................................................................................................................................... 5  FINRA RULE 4370 .................................................................................................................................................... 6  FURTHER INFORMATION ............................................................................................................................................ 6  EMERGENCY CONTACT PERSONS.......................................................................................................... 6  SPECIFIC COMPLIANCE............................................................................................................................................... 6  PLAN PROCEDURES .................................................................................................................................................... 7  FIRM POLICY ............................................................................................................................................... 7  SPECIFIC COMPLIANCE............................................................................................................................................... 7  PLAN POLICY AND ACCOMPANYING PROCEDURES .................................................................................................... 7  Significant Business Disruptions (SBDs) .............................................................................................................. 8  Approval and Execution Authority ........................................................................................................................ 8  Plan Location and Access ..................................................................................................................................... 8  BUSINESS DESCRIPTION .......................................................................................................................... 8  SPECIFIC COMPLIANCE............................................................................................................................................... 8  BUSINESS DESCRIPTION ............................................................................................................................................. 8  OFFICE LOCATIONS ................................................................................................................................... 9  SPECIFIC COMPLIANCE............................................................................................................................................... 9  OFFICE LOCATIONS .................................................................................................................................................... 9  Main OSJ Location ............................................................................................................................................... 9  Branch Location #1 (OSJ) .................................................................................................................................. 10  Branch Location #2 (Non-OSJ) .......................................................................................................................... 10  Branch Location #3 (Non-OSJ) .......................................................................................................................... 10  Branch Location #4 (Non-OSJ) .......................................................................................................................... 10  Unregistered Office Location #5......................................................................................................................... 11  Unregistered Office Location #6......................................................................................................................... 11  Unregistered Office Location #7......................................................................................................................... 11  ALTERNATIVE PHYSICAL LOCATION(S) OF EMPLOYEES ................................................................. 11  SPECIFIC COMPLIANCE............................................................................................................................................. 11  LOCATION/PLAN ...................................................................................................................................................... 11  CLIENTS’ ACCESS TO FUNDS AND SECURITIES ................................................................................. 11  SPECIFIC COMPLIANCE............................................................................................................................................. 12  PLAN ........................................................................................................................................................................ 12  DATA BACK-UP AND RECOVERY [HARD COPY AND ELECTRONIC] ................................................ 12  SPECIFIC COMPLIANCE............................................................................................................................................. 12  BACK-UP LOCATIONS AND MEDIA TYPE .................................................................................................................. 12  FINANCIAL AND OPERATIONAL ASSESSMENTS ................................................................................ 13  SPECIFIC COMPLIANCE............................................................................................................................................. 13  OPERATIONAL RISK ................................................................................................................................................. 13  FINANCIAL & CREDIT RISK ...................................................................................................................................... 14  MISSION CRITICAL SYSTEMS ................................................................................................................. 14 

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SPECIFIC COMPLIANCE............................................................................................................................................. 14  INTRODUCTION/EXPLANATION ................................................................................................................................ 14  ORDER TAKING ........................................................................................................................................................ 15  ORDER ENTRY ......................................................................................................................................................... 15  ORDER EXECUTION .................................................................................................................................................. 15  MISSION CRITICAL SYSTEMS PROVIDED BY CLEARING FIRM .................................................................................. 15  ALTERNATE COMMUNICATIONS BETWEEN THE FIRM AND CLIENTS, EMPLOYEES, AND REGULATORS ........................................................................................................................................... 16  SPECIFIC COMPLIANCE............................................................................................................................................. 16  CLIENTS ................................................................................................................................................................... 16  EMPLOYEES ............................................................................................................................................................. 16  REGULATORS ........................................................................................................................................................... 16  CRITICAL BUSINESS CONSTITUENTS, BANKS, AND COUNTER-PARTIES ...................................... 17  SPECIFIC COMPLIANCE............................................................................................................................................. 17  BUSINESS CONSTITUENTS ........................................................................................................................................ 17  Major Suppliers .................................................................................................................................................. 17  BANKS ..................................................................................................................................................................... 17  COUNTER-PARTIES .................................................................................................................................................. 18  REGULATORY REPORTING..................................................................................................................... 18  SPECIFIC COMPLIANCE............................................................................................................................................. 18  REPORTING PROCEDURES ........................................................................................................................................ 18  Federal Regulators and SROs ............................................................................................................................ 18  State Regulators .................................................................................................................................................. 19  DISCLOSURE OF BUSINESS CONTINUITY PLAN ......................................................................................................... 19  UPDATES AND ANNUAL REVIEW ........................................................................................................... 19  SPECIFIC COMPLIANCE............................................................................................................................................. 19  POLICY ..................................................................................................................................................................... 20  SENIOR MANAGER APPROVAL .............................................................................................................. 20  ATTESTATION .......................................................................................................................................................... 20  SIGNATURE .............................................................................................................................................................. 20  NAME OF MANAGER ................................................................................................................................................ 20  TITLE ....................................................................................................................................................................... 20  DATE........................................................................................................................................................................ 20  APPENDIX A .............................................................................................................................................. 21 

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INTRODUCTION TriPoint Global Equities, LLC (the “Firm”), has developed this “Business Continuity Plan” to assist both Designated Supervisors and all relevant associated persons in understanding and executing their respective responsibilities and duties to the Firm, to the self regulatory body of which the Firm is a member, to the investment community at large, and specifically and most importantly, to the investors who have placed their trust in the Firm and its ability to conduct itself consistent “with just and equitable principles of trade.” “The obligation to develop a BCP is not a ‘one-size-fits-all’ requirement, and you must tailor your plan to fit your particular firm’s situation.” All quoted language contained in this “Business Continuity Plan” as may be included from to time, may be taken from Securities and Exchange Commission (“SEC”), Municipal Securities Rulemaking Board (“MSRB”) or Financial Industry Regulatory Authority, Inc. (“FINRA”) laws, rules and/or regulations, as the case may be. In most cases, however, information gleaned from the laws, rules and regulations was extrapolated and made more concise for inclusion in this plan.

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GENERAL COMPLIANCE ANALYSIS FINRA Rule 4370 General Requirements FINRA Rule 4370 requires that the Firm create and maintain this written BCP identifying procedures relating to an emergency or significant business disruption. Within reason, this plan must be designed to enable the Firm to meet its existing obligations to clients. This plan must address our relationship with other broker-dealers, including our clearing firm(s), and counter-parties. This plan shall be available at all times and delivered “promptly” to FINRA staff upon request. The Firm is required to update this plan periodically in the event of any material change to our operations, structure, business or location. The Firm shall also conduct an annual review of this business plan to determine whether any modifications are necessary. While the plan should be flexible enough to address issues specific to the Firm, it must also address the following items, which are listed and required in and by Rule 4370, to the extent they are applicable and necessary to the Firm’s conduct of business. The Firm must document its rationale for not including any of the categories below: 1) Data back-up and recovery (hard copy and electronic); 2) All mission critical systems; 3) Financial and operational assessments; [Rule 4370 defines this to mean “a set of written procedures that allow a member to identify changes in its operational, financial, and credit risk exposures.”] 4) Alternate communications between clients and the Firm; 5) Alternate communications between the Firm and its employees; 6) Alternate physical location of employees; 7) Critical business constituent, bank, and counter-party impact; 8) Regulatory reporting; 9) Communications with regulators; and 10) How the Firm will assure clients' prompt access to their funds and securities in the event that the member determines that it is unable to continue its business. Because the Firm is an introducing broker, we shall rely on our clearing firm(s)’s business continuity plan for addressing a number of the above-listed categories or any mission critical system. Our relationship is addressed below. Availability of BCP This plan shall be available at all times and delivered promptly to FINRA staff upon request. Regular Updates of BCP The Firm is required to update this plan periodically in the event of any material change

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to its operations, structure, business or location. The Firm shall also conduct an annual review of this business plan to determine whether any modifications are necessary. Designation of Person Responsible for BCP The Firm is required to designate a General Securities Principal who is also a member of the senior management team to approve this plan. This person shall be responsible for conducting the required annual review. BCP Disclosure Requirement The Firm must also disclose to our clients how this plan addresses the possibility of a future significant business disruption and how we plan to respond to various events. The Firm shall send its disclosure to any client who so requests. The Firm is required to designate a General Securities Principal who is also a member of our senior management team to approve this plan. This person shall be responsible for conducting the required annual review. FINRA Rule 4370 Emergency Contact Information Reporting FINRA Rule 4370 requires the Firm to report the Firm’s emergency contact information to FINRA. The reporting is done via the FINRA Contact System (“FCS”), a Web-based platform created and administered by FINRA. The Firm is required to designate two emergency contact persons. Where possible, both contact persons shall be principals of the Firm. Emergency Contact Information Updates The Firm is required to update its emergency contact information, including designation of two emergency contact persons, within 17 business days after the end of each calendar year (the “Annual Review”) to ensure the information's accuracy. The Firm’s Executive Representative, or his or her designee, which designation must be in writing, must conduct such review and any update. The Firm must ensure that only the Executive Representative, or his or her written designee, may perform this review and update. Further Information For more information regarding BCP see NASD Notice to Members 04-37.

EMERGENCY CONTACT PERSONS Specific Compliance FINRA Rule 4370. The Firm must designate two emergency contact persons, and must update these names in the event of a material change in Firm personnel. The Firm’s Executive

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Representative or a designee must review quarterly the currency of each designated contact person within 17 business days of the end of each quarter via the FCS. If possible, each emergency contact person must be a member of senior management and a registered principal. If there is only one registered principal at the Firm, the second emergency contact person should be another Firm employee. If at any time our Firm has only one individual associated with it, the second emergency contact should be an individual, who has knowledge of our Firm’s business operations, such as our attorney or accountant. Plan Procedures The Firm’s two emergency contact persons are: NAME: Mark H. Elenowitz NAME: Michael R. Boswell TEL # Primary: (212) 732-7184 TEL # Primary: (240) 864-0449 TEL # Alternate: (516) 987-3155 TEL # Alternate: (301) 318-5239 FAX # Primary: (646) 786-3454 Fax # Primary: 646 786-3454 E-MAIL 1: E-MAIL 1: [email protected] [email protected] E-MAIL 2: E-MAIL 2: [email protected] [email protected] POSITION WITH FIRM: President, COO POSITION WITH FIRM: Chief Executive Officer and Chief Compliance Officer The Firm shall update these names in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each quarter via FCS. The Firm has also initiated an Employee Call Tree which enables Firm personnel to contact one another in case of a disruption to the Firm’s ability to conduct business.

FIRM POLICY Specific Compliance The Firm shall state in its BCP its objectives with respect to both internal and external significant business disruptions (“SBDs”). The Firm shall state our obligation to grant clients access to their funds and securities in the event of SBDs. The Firm shall ensure that all employees have access to and have reviewed this Plan. The Firm shall state who has the authority to execute this Plan, where the Plan is stored, and how to access the Plan. Plan Policy and Accompanying Procedures In the event of a SBD, the Firm shall above all else seek to safeguard the lives of its personnel. The Firm shall then make a financial and operational assessment pursuant to Section IX below. The Firm shall then seek to safeguard the Firm’s books and records, other firm property, quickly recover and resume operations in a safe manner,

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all to enable clients to continue to transact business. Should the Firm determine that we cannot continue to conduct business, we will assure clients prompt access to their funds and securities via our clearing firm(s). Significant Business Disruptions (SBDs) The Firm’s plan addresses both internal and external SBDs. Internal SBDs, such as, for example, fire, power outage, or office flooding, that affect only the Firm’s ability to communicate and do business. External SBDs prevent or may severely hinder the operation of the securities markets as a whole, or a specific segment of the market that directly affects our Firm, such as a terrorist attack, a city-wide flood, or a regional power blackout. The Firm’s response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm(s). Approval and Execution Authority Michael R. Boswell, the Firm’s President, COO and Chief Compliance Officer, is responsible for approving the plan and for conducting the required annual review. Michael R. Boswell, President, COO and CCO, has the authority to execute this plan. Plan Location and Access The Firm will maintain copies of this plan, the annual reviews, and all other periodic changes that have been made to it. The Firm has given or shall give the FINRA District 10, New York Office a copy of this plan. An electronic copy of this plan is located on the firm’s computer server and is also kept in electronic form with our service provider, Modern Regulatory Services LLC (“ModernRS”). ModernRS maintains a copy of this plan on an offsite server.

BUSINESS DESCRIPTION Specific Compliance The Firm shall state the complete list of business types as they appear of the Firm’s Form BD. Similarly, the Firm shall make certain with respect to the business types it is allowed to conduct pursuant to its Membership Agreement, and to non-material changes made in its business conduct, that its Form BD is always up to date as is required by FINRA rules and pursuant to the Firm’s Written Supervisory Procedures. Business Description The Firm primarily conducts a business in the following areas:  Private placements of securities  Other: The Firm offers corporate finance consulting that may include from time to

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        

time consultation regarding mergers and/or acquisitions. Other: The Firm shall provide advice to the issuer of securities in potential public offerings, and making referrals to the issuer of a lead underwriter. Underwriter or selling group participant on a best efforts basis Broker or dealer retailing corporate equity securities over-the-counter Broker or dealer selling corporate debt securities Non-exchange member arranging for transactions in listed securities by exchange member In-house research Mutual fund retailer Put & call broker or dealer or option writer Municipal securities broker

The Firm is an introducing firm and does not perform any type of clearing function for itself or others. The Firm neither holds client funds or securities. The Firm accepts and enters orders. All transactions are sent to our clearing firm(s), which executes our orders, compares them, allocates them, clears and settles them. Our clearing firm(s) also maintains our clients’ accounts, can grant clients access to them, and delivers funds and securities. Our Firm services only institutional clients. The Firm’s clearing firm is FolioFn Investments, Inc. information is 8180 Greensboro Drive, 8th www.folioinvesting.com, 703-245-4000.

Foliofn Investments, Inc. contact Floor, Mclean, VA 22102,

TFP Holdings, LLC is the 100% owner of the Firm as listed on Schedule A of Form BD. Michael R. Boswell is the President, COO and Chief Compliance Officer of the Firm. Mark H. Elenowitz is the Chief Executive Officer of the Firm. Tracie Erin O’Keefe is the Financial & Operations Principal of the Firm.

OFFICE LOCATIONS Specific Compliance The Firm shall list all locations, whether registered or unregistered, where in conducts business. Similarly, the Firm shall make certain with respect to office and branch locations, that its Form BD is always up to date as is required by FINRA rules and pursuant to the Firm’s Written Supervisory Procedures. Office Locations The Firm has the below listed offices. The Firm has no other offices, registered or unregistered. Main OSJ Location

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The Firm’s main OSJ location is located at 1450 Broadway, 26th FL, New York, NY 10018. Its main telephone number is (212) 732-7184, which rings at both the main and branch locations. The Firm’s employees may travel to this office by means of foot, car, subway, train, or bus. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, e-mail and order taking and entry at this location. Branch Location #1 (OSJ) The Firm’s Branch Location #1 is located at 400 Professional Drive, Suite 310 Gaithersburg, MD 20879. Its main telephone number is (240) 864-0449. The Firm’s employees may travel to this office by means of foot or car. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail. Branch Location #2 (Non-OSJ) The Firm’s Branch Location #2 is located at Level 15, Yin Tai Centre, No. 2 Jian Guo Men Wai Avenue, Beijing, China 100022. Its main telephone number is +86 (10) 65637940. The Firm’s employees may travel to this office by means of car or any reasonably available means. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail. Branch Location #3 (Non-OSJ) The Firm’s Branch Location #3 is located at 390 N. Broadway, Suite 120, Jericho, NY 11753. Its main telephone number is (516) 605-1984. The Firm’s employees may travel to this office by means of car or any reasonably available means. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail. Branch Location #4 (Non-OSJ) The Firm’s Branch Location #4 is located at 1611-A Akron Peninsula Rd., Akron, OH 44313. Its main telephone number is (330) 475-1690. The Firm’s employees may travel to this office by means of car or any reasonably available means. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail.

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Unregistered Office Location #5 The Firm’s Unregistered Location #5 is located at 833 Autry Oak Ct., Alphareta, GA 30022. Its main telephone number is (770) 326-9427. The Firm’s employees may travel to this office by means of car or any reasonably available means. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail. Unregistered Office Location #6 The Firm’s Unregistered Location #6 is located at 125 S. Jefferson St., Unit 1208, Chicago, IL 60661. Its main telephone number is (312) 450-4732. The Firm’s employees may travel to this office by means of car or any reasonably available means. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail. Unregistered Office Location #7 The Firm’s Unregistered Location #7 is located at 501 B Boush Street, Norfolk, VA 23510. Its main telephone number is (917) 318-1080. The Firm’s employees may travel to this office by means of car or any reasonably available means. The Firm engages in the following business at this location: all previously listed business types. The Firm views the following systems as critical to the conduct of the above stated business at this location: telephone, computer, and e-mail.

ALTERNATIVE PHYSICAL LOCATION(S) OF EMPLOYEES Specific Compliance FINRA Rule 4370(c)(6). The Firm shall list the alternate physical location or locations that it will use should a SBD affect the operation of its main and branch office locations. Location/Plan In the event of such a disruption to the Firm’s offices, the Firm will move its staff to the remaining unaffected office.

CLIENTS’ ACCESS TO FUNDS AND SECURITIES

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Specific Compliance FINRA Rule 4370(c)(10); Securities Exchange Act Rule 15c3-1. If applicable to the Firm’s business, it shall state how it will make client funds and or securities available to them in the event of a SBD and shall state the entity at which such funds and securities are held, and how the Firm will attempt to facilitate client access to them. The Firm shall describe any relationship between its ability to grant client access to funds and securities and Securities Investor Protection Corporation (SIPC) regulations on the disbursement of funds and securities. Plan The Firm does not maintain custody of clients’ funds or securities, which are maintained at our clearing firm(s), Folionfn Investments, Inc. In the event of a SBD, if telephone service remains available, the Firm’s registered representatives will continue to take client orders or instructions and contact our clearing firm(s) on the client’s behalf. If the Firm’s telephones are not operational, the Firm will post on its Web site that clients may access their funds and securities by contacting Foliofn Investments, Inc. The Firm will make this information available to clients through its Summary Disclosure Statement. If SIPC determines that the Firm is unable to meet its obligations to clients or if the Firm’s liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1 (Net Capital), SIPC may seek to appoint a trustee to disburse our assets to clients. We will assist SIPC and the trustee by providing our books and records identifying client accounts subject to SIPC regulation.

DATA BACK-UP AND RECOVERY [HARD COPY AND ELECTRONIC] Specific Compliance FINRA Rule 4370(c)(1). The Firm shall identify the location of its primary books and records (hard copy and electronic) and the location of its back-up books and records (hard copy and electronic). The Firm shall describe how it backs up its data, and in addition, describe how it will recover data in the event of a SBD. Back-up Locations and Media Type The Firm maintains its primary hard copy books and records and its electronic records at principal office location and the Maryland branch office location. Mark H. Elenowitz, CEO is responsible for the maintenance of these books and records at the principal office and Michael R. Boswell, President, COO and CCO, is responsible for the maintenance of these books and records at the branch office.

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The Firm does not back up paper to paper. However, hard copy books and records are scanned and stored on the hard drive, and backed up with the electronic records. The Firm backs up its electronic records in secure sites hourly each day between 8 am and 10 pm (16 times). The Firm retains all of its electronic communications utilizing electronic storage media, and relies upon a 3rd party service provider (Enobis LLC) to archive, retain and preserve the information. Certain of the Firm’s compliance records are backed up by ModernRS. ModernRS maintains a copy of the Firm’s Written Supervisory Procedures, Continuing Education Plan, Anti-Money Laundering Procedures, among other documents, on an offsite server. In the event of a SBD that causes the loss of our paper records, the Firm will access the electronic copies and restore the paper records from them. If the Firm’s primary site is inoperable, it will continue operations from its back-up site or an alternate location. For the loss of electronic records, the Firm will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.

FINANCIAL AND OPERATIONAL ASSESSMENTS Specific Compliance FINRA Rules 4370(c)(3), (c)(8), (f)(2) & (g)(2). The Firm shall describe procedures to identify changes in its operational, financial, and credit risk exposures in the event of a SBD. The Firm should periodically assess the changes in the above, and quickly make such an assessment in connection with a SBD. Operational risk includes the Firm’s ability to maintain communications with clients and to retrieve key activity records through its mission critical systems. Financial risk involves the Firm’s ability to fund operations and maintain adequate financing and sufficient capital. The Firm also may face credit risk (where its investments may erode from the lack of liquidity in the broader market), which would also hinder the ability of the Firm’s counter-parties to fulfill their obligations. Operational Risk Should a SBD occur, the Firm will immediately identify what measures to take that will permit the Firm to communicate with our clients, employees, all critical third-parties, and regulators. The intensity of the SBD will determine the methods of alternative communication. The Firm could currently employ the following communications options: Web site, telephone voice mail, secure e-mail, etc. In addition, the Firm could retrieve its key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).

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Financial & Credit Risk Should a SBD occur, the Firm will determine the value and liquidity of its capital structure investments and other assets to evaluate its ability to continue to fund operations and remain in capital compliance. The Firm will contact its clearing firm(s), critical banks, and investors to apprise them of the Firm’s financial status. If the Firm determines that it may be unable to meet its obligations to those counter-parties or otherwise continue to fund its operations, it will request additional financing from its bank or other credit sources to fulfill its obligations to its clients. If the Firm cannot remedy a capital deficiency, it will file appropriate notices with our regulators and immediately take appropriate steps to provide clients with alternate methods of conducting their securities transactions.

MISSION CRITICAL SYSTEMS Specific Compliance FINRA Rules 4370(c)(7) & (g)(1). The Firm shall describe its mission critical systems and whether it or its clearing firm(s) has responsibility for them. The Firm shall review its clearing firm(s)’s capabilities to perform their mission critical functions for the Firm. The Firm shall focus on the recovery of mission critical systems after a SBD and the time it takes to resume active communications with the Firm’s clients. Introduction/Explanation The Firm’s “mission critical systems” are those that maintain: 1. Prompt and accurate processing of securities transactions, which include: a. order taking, b. entry of securities transactions. These systems include: 1. phone The Firm has primary responsibility for establishing and maintaining our business relationships with our clients and has sole responsibility for our mission critical functions of order taking and entry. The Firm’s clearing firm(s) provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. The severity and timing of a SBD and its effect on the Firm’s critical infrastructure— particularly telecommunications—can affect actual recovery times. Recovery refers to

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the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Order Taking The Firm receives orders from customers via BANQ® electronic web site. During a SBD, the Firm will continue to take orders through whichever of these methods are available and reliable, and, when possible, will inform clients when alternative communications become available to assist the client in processing their orders as expeditiously as possible. If necessary, the Firm will advise clients to place orders directly with the Firm’s clearing firm(s). Order Entry Currently, the customer enters orders electronically on www.banq.co which directly sends them to our clearing firm(s) electronically. Alternatively, the Firm can place customer orders through our clearing firm(s)’s trading system. In the event of an internal SBD, the Firm will enter and send records to its clearing firm(s) by the fastest alternative means available, which include direct entry, email, fax, and phone. In the event of an external SBD, the Firm will maintain the order in electronic or paper format, and deliver the order to the clearing firm(s) by the fastest means available when it resumes operations. In addition, during an internal SBD, the Firm may need to refer clients to deal directly with the clearing firm(s) for order entry. Order Execution Currently, the customer enters orders electronically on www.banq.co which directly sends them to our clearing firm(s) electronically. Alternatively, the Firm can place customer orders through our clearing firm(s)’s trading system. In the event of an internal SBD, the Firm will enter and send records to its clearing firm(s) by the fastest alternative means available, which include direct entry, telephone, fax, and email. In the event of an external SBD, the Firm will maintain the order in electronic, and deliver the order to the clearing firm(s) by the fastest means available when it resumes operations. In addition, during an internal SBD, the Firm may need to refer clients to deal directly with the clearing firm(s) for order entry. Mission Critical Systems Provided by Clearing Firm The Firm relies on its clearing firm(s), via it clearing agreement, to provide order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.

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ALTERNATE COMMUNICATIONS BETWEEN THE FIRM AND CLIENTS, EMPLOYEES, AND REGULATORS Specific Compliance FINRA Rule 4370(c)(4), (5) & (9) The Firm shall describe the alternate means of communications that it will use to communicate with its clients in the event of a SBD, and shall describe as well the alternate means of communications that it will use to communicate with its employees, and with regulators, in the event of a SBD. Clients The Firm communicates with its clients using the telephone, e-mail, fax, U.S. mail, and in person visits at the Firm or at the other’s location. Should a SBD occur, the Firm will assess which means of communication are still available, and use that which is most similar to our normal communications with that particular client. Employees The Firm communicates with its employees using the telephone, e-mail, and in person. Should a SBD occur, the Firm will assess which means of communication are still available and use that which is most similar to our normal communications with that particular employee. The Firm shall also employ a call tree so that senior management can reach all registered representatives and any critical personnel quickly during a SBD. The Firm shall attach a list containing the names and contact information of these individuals to this BCP. The person to invoke use of the call tree is: Mark H. Elenowitz or Michael R. Boswell.

Mark H. Boswell

Caller Elenowitz or

Michael

Call Recipients R. All other registered representatives and any critical personnel (see attached).

Regulators The Firm is currently a member of the Financial Industry Regulatory Authority, Inc. (FINRA) and is regulated by the Securities and Exchange Commission (SEC). The Firm communicates with the SEC and the FINRA via the telephone, e-mail, fax, U.S. mail, and in person. Should a SBD occur, the Firm will assess which means of communication are still available, and use that which is most similar to our normal communications with that particular organization.

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CRITICAL BUSINESS CONSTITUENTS, BANKS, AND COUNTERPARTIES Specific Compliance Rules 4370(a) & (c)(7) The Firm shall describe its procedures to identify how a SBD will impact its relationships with its critical business constituents, banks, and counter-parties, and how it will deal with those impacts. Business Constituents The Firm has contacted its critical business constituents with which the Firm has an ongoing commercial relationship in support of its operating activities in order to determine the extent to which it can continue a business relationship with them in light of an internal or external SBD. The Firm shall quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services required because of a SBD affecting that business or the Firm. Major Suppliers Business Modern Regulatory Services LLC

Product Broker-Dealer Compliance

Foliofn Investments, Inc. Enobis LLC

Clearing Firm Electronic Storage Media

Address Administrative Office 225 Brewers Bridge Rd. Suite B1 Jackson, NJ 08527 8180 Greensboro Drive, 8th Floor, Mclean, VA 22102 400 Professional Drive, Suite 310, Gaithersburg, MD 20879-3454

Telephone (800) 9210175 703-245-4000 (240) 4031681

Banks The bank maintaining the Firm’s operating account is: Mid-Atlantic Federal Credit Union, 555 Quince Orchard Road, Gaithersburg, Maryland 20878, Contact: Sergio Gagliardi, (301) 944-1800, [email protected]. The bank maintaining the Firm’s second operating account is: Citibank, 1440 Broadway, New York, NY 10018, Contact: Michael J Koontz, (646) 728-0312, [email protected]. Should the Firm require normal or additional financing that we will need in light of an internal or external SBD, the Firm’s banks and other lenders will provide it. If this is not possible, Mark H. Elenowitz and Michael R. Boswell have significant assets and liquidity, and will provide the Firm with the required financing. 17

Counter-Parties The Firm has contacted its critical counter-parties, such as other broker-dealers or institutional customers, to determine if the Firm will be able to carry out transactions with them in light of an internal or external SBD. Where the transactions cannot be completed, the Firm will work with its clearing firm(s) or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible.

REGULATORY REPORTING Specific Compliance FINRA Rule 4370(e). 4370(c)(8). The Firm shall describe how it will file its regulatory reports in the event of a SBD. The Firm shall describe how it will disclose its business continuity planning to clients, and shall include the current version of its Summary Disclosure Statement. With regard to the summary disclosure statement, the Firm may include cautionary language in the summary that the plan is subject to modification, that an updated summary will be promptly posted on your Web site, and that clients may alternatively obtain updated summaries by requesting a written copy by mail. Reporting Procedures The Firm files reports with the FINRA and SEC using the FINRA-administered Regulation Form Filing, Web CRD, Web IR, FCS platforms, which are all web-based forms of delivery. Periodically, the Firm may use fax or e-mail to communicate with either organization. Should a SBD occur, the Firm will contact the SEC, FINRA, and other regulators to determine which means of reporting are still available, and use that which is most similar to our normal reporting method with that particular organization. In the event the Firm cannot contact its regulators, it will continue to file required reports using the most suitable methods available. The Firm is subject to regulation by:

Federal Regulators and SROs Name of Organization Securities and Exchange Commission Financial Industry Regulatory Authority, Inc.

Address 450 5th Street, NW Washington, DC 20549 District 10 Office One World Financial Center

Telephone (202) 942-8088 (212) 858-4000

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FINRA Call Center

200 Liberty Street New York, NY 10281 Rockville, Maryland

301-590-6500

State Regulators Please refer to http://www.nasaa.org/about_nasaa/2062.cfm for contact information for all state regulators. Disclosure of Business Continuity Plan The Firm discloses in writing a summary of this plan to clients at account opening and annually. The Firm also posts the summary on our Web site and mails it to customers upon request. The summary addresses the possibility of a future SBD and how the Firm plans to respond to varying events. In addressing these events, the summary: (1) provides specific scenarios of varying severity such as, a firm-only business disruption, a disruption to a single building, a disruption to a business district, a citywide business disruption, and a regional disruption; (2) states whether the Firm plans to continue business during a particular scenario and, if so, the Firm’s planned recovery time; and (3) provides general information on our intended response. The Firm’s summary discloses the existence of back-up facilities and arrangements, but does not disclose the specific location of any back-up facilities, any proprietary information contained in the plan or the parties with whom the Firm has back-up arrangements. The Firm shall include cautionary language in the summary that the plan is subject to modification, that an updated summary will be promptly posted on your Web site, and that clients may alternatively obtain updated summaries by requesting a written copy from the Firm by mail. The Firm Summary Disclosure Statement shall be appended to this plan as Appendix A.

UPDATES AND ANNUAL REVIEW Specific Compliance FINRA Rule 4370(b). The Firm shall describe its plan update policy and annual review of this plan.

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Policy The Firm will update this plan whenever it has a material change to its operations, structure, business or location or to those of its clearing firm(s). The Firm will review this plan annually to modify it for any changes in operations, structure, business, or location or those of its clearing firm(s).

SENIOR MANAGER APPROVAL Attestation Pursuant to FINRA Rule 4370(d), I have approved this Business Continuity Plan as reasonably designed to enable the Firm to meet its obligations to clients in the event of a SBD. Signature

Name of Manager Michael R. Boswell Title President and Chief Compliance Officer Date

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APPENDIX A TRIPOINT GLOBAL EQUITIES, LLC BUSINESS CONTINUITY PLAN SUMMARY DISCLOSURE STATEMENT TriPoint Global Equities, LLC (“TriPoint”), pursuant to Financial Industry Regulatory Authority, Inc. (“FINRA”) rules, has created a Business Continuity Plan, to address and guide our response to and recovery from Significant Business Disruptions (“SBDs”). Copies of this Summary Disclosure Statement shall be given to all clients at the time they open their accounts with TriPoint. TriPoint’s Business Continuity Plan is subject to modification. Clients may obtain updated summaries by requesting a written copy by mail or fax. In all of the following scenarios, TriPoint plans to continue business and our planned recovery time, depending upon the time of occurrence, should not exceed 24 hours from the time of the declaration of the SBD. Staff, telephone calls, and e-mails will return to their original location upon full restoration of service. Disruption to a single building or our Firm’s main or branch offices If a disruption occurs at our main office located at 1450 Broadway, 26th FL, New York, NY 10018 or our branch offices located at 400 Professional Drive, Suite 310, Gaithersburg, MD 20879, Level 15, Yin Tai Centre, No. 2 Jian Guo Men Wai Avenue, Beijing, China 100022, 390 N. Broadway, Suite 120, Jericho, NY 11753 and 1611-A Akron Peninsula Rd., Akron, OH 44313, we will move to an unaffected location. This location may be another of the firm’s offices or the home office of firm personnel. Disruption to a business district If a disruption occurs in our business district affecting our main and branch offices, we will move to an unaffected location. This location shall be outside the business district and may be another of the firm’s offices or the home office of firm personnel. City-wide business disruption If a disruption occurs in our city-wide area that affects our main and branch offices, we will move to an unaffected location. This location shall be outside the city-wide area and may be another of the firm’s offices or the home office of firm personnel. Regional disruption If a regional disruption occurs that affects our main and branch offices, we will move to an unaffected location. This location shall be outside the regional area and may be another of the firm’s offices or the home office of firm personnel.

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TriPoint has also contracted with various entities to insure that sensitive information is made redundant at back-up facilities. However, due to the nature of such information we do not disclose the specific location of any back-up facilities, any proprietary information contained in our Business Continuity Plan or the parties with whom we have back-up arrangements. Please call us should you have any questions at (212) 732-7184. Thank you.

Michael R. Boswell President and Chief Compliance Officer TriPoint Global Equities, LLC

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