Primex Prime Electronic Execution Incorporated (“PMMX”)
A Summary of Our Business Continuity Plan

Introduction:

It is now more important than ever that companies take steps to prepare for unexpected events such as natural disasters, terrorist attacks, power and/or network outages, fires, etc. PMMX wants its customers and business partners to know that it has developed comprehensive business continuity plans designed to minimize the effects of these significant business disruptions.


Our Business:

PMMX, a registered broker-dealer, supports a diverse array of businesses with and through its clearing firm Sterne Agee & Leach Clearing. (“Sterne Agee ”) enterprise. PMMX is, for example, a distributor of mutual funds and group variable annuity products, an introducing broker for retirement plans, a clearing broker for certain mutual fund wrap fee programs, and a full-service Broker Dealer. Its registered representatives offer, individual clients and/or to institutions, a variety of securities products, including stocks, bonds, mutual funds, separately managed accounts, retirement plan securities, limited partnerships, and more. We have offices and operations throughout the United States, but are primarily located in the Northeast with our largest offices in New York and New Jersey. Each PMMX office maintains its own business continuation plan that provides for alternative operating sites, back-up facilities and systems.


Overview of Our Business Continuity:

PMMX, has access to extensive resources, both in terms of alternate physical locations from which to conduct business, as well as systems resources to provide disaster recovery planning. Because PMMX conducts its business activities from multiple locations, it has made arrangements to relocate associates to one of several backup locations in the event that a primary work location is unavailable. In the following sections A – C, we describe how our Business Continuity Plan will be deployed in a variety of potential business disruption scenarios.


A. Disruption to One or More PMMX Offices

Impacted associates whose functions are deemed critical report to a designated recovery site, which is designed to be operational within 24 hours. Other associates may be directed to one of several alternate sites, which are designed to be operational within 48 hours after a disruptive event. And in some cases, associates can work from home. Essential information systems and data are similarly restored and made available thanks to regularly tested backup and recovery procedures.


B. Disruption To A Business District or City

Certain designated backup sites may be located within the same business district or city as a primary work location. In the event one or more backup sites are unavailable, impacted associates would utilize an alternate site outside the business district or city, or in some cases, they may work from home. For example, associates from PMMX’ main office in New York may be directed to one of several other proprietary or third party locations in New York, New Jersey or other states, depending on availability. Our goal is to provide critical personnel an operational backup site within 24 hours, and other associates within 48 hours.


C. Disruption To An Entire Region

As discussed above, multiple backup locations are typically available to PMMX associates in the event of a disruptive event. In the event no designated site is available due to a large-scale disruptive event, it may be necessary for PMMX to suspend its operations until alternate arrangements can be made. As discussed in PMMX’ Business Continuity Plan, PMMX will maintain communications with and assist its customers and business partners to the best of its ability in the circumstances. While we strive to restore our operations within 24 to 48 hours, our actual recovery time will depend on the nature and extent of the business disruption.


Market Closings:

Certain PMMX businesses may be dependent on the availability of U.S. securities markets and trading facilities. For example, PMMX may be unable to complete transactions in mutual funds if the National Securities Clearing Corporation, or NSCC, is not operational.


Systems Recovery:

PMMX utilizes a network of systems and data that is supported by an extensive IT organization. Applications are backed up frequently and in some cases, critical transactions are replicated in real time at an alternate data center. In addition, backup and recovery procedures are documented in comprehensive written plans that are updated and tested on a regular basis.


Other Privacy Policies or Statements; Changes to Policy

This policy provides a general statement of the ways in which Primex protects your personal information. You may, however, in connection with specific products or services offered by Primex, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective June 14, 2008.


Clearing Relationships:

In its full service brokerage business, PMMX acts as introducing broker to a clearing firm, Sterne Agee Clearing (“SAC”). If your transactions are cleared through SAC, and in the event of a significant disruption, our registered persons will accept orders at 877-678-9830 and contact SAC on your behalf.


Contact for Further Information:

PMMX is committed to meeting its obligations to customers and business partners. Its business continuity plans may change from time to time. PMMX will post important information regarding its business continuity plans on the Primex website (www.primexprime.com). In addition, you may obtain related information by writing to Primex at Forty Five Knollwood Road, 4th Floor, Elmsford, NY 10523. PMMX is a member of SIPC.

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