Continuity Plan

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Rockwell Financial Group Business Continuity Plan 

Emergency Contact Persons Rockwell Financial Group has two emergency contact persons: 

Michael Halkitis, 

President/ Finop Primary Contact Information: Phone 516 499 9453

mhalkitis@therockwellfinancialgroup.com 

Secondary Contact Info: Phone 888 574-0100 

Hugh D. Dunn, Jr., Vice President/Chief Compliance Officer Primary Contact Information: 

Phone 914 328-7030 hdunn@therockwellfinancialgroup.com 

Secondary Contact Information: Phone 888 791-8877 

These names will be updated in the event of a material change. The information is reviewed within 17 days of the end of each quarter. Firm Policy Our Firms policy in a Significant Business Disruption (SBD) is: 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. Significant Business Disruptions (SBDs) Significant Business Disruptions can vary in their scope. They can be internal or external. In all likelihood an internal disruption would affect only our firm. Our response to an internal disruption should be quicker than an external disruption that may affect more than one firm or the securities markets as a whole. Our response to an external disruption would rely more heavily on our clearing firm and their systems. Approval and Execution Authority Michael Halkitis, President, and Hugh Dunn, Jr., Chief Compliance Officer are responsible for approving the plan and for conducting the required annual review. They have the authority jointly and individually to execute this BCP. Plan Location and Access We will maintain copies of the BCP and the annual review at both the main office and the OSJ Branch where Messrs Dunn operate. An electronic copy will be kept on a form of electronic storage offsite. Business Description We conduct a business in equity, fixed income, mutual funds, etc. We are an introducing firm and do not perform any type of clearing function. We do not accept or hold customer funds or securities. We accept and enter orders on behalf of our customers. All transactions are sent to our clearing firm, who in turn executes compares, allocates, clears and settles them. They maintain our customer accounts. They can grant our customers access to their accounts as well as deliver funds and securities. We service retail customers. The clearing firm is Hilltop Securities, 1201 Elm Street, Suite 3500 Dallas, TX 75270. Main Office Phone Number: (214) -953-4000. Their website www.hilltopsecurities.com Through Our liaison to Hilltop Securities, we have received from Hilltop Securities a BCP Summary that includes the following: Mission Statement Planning Structure and Basic Assumptions Event Management Structure Incident Management Team Response Teams Business Units Line Managers Business Continuity Team Captains IMT Liaison Communications with Customers Outbound Communications Account Managers and Customer Service Associates Inbound Communications Problem Notification Security Policies Data Security Physical Security Access Business Continuity Business Continuity Plans Recovery Sites Testing Disaster Recovery Mainframe Distributed Systems Network Testing Office Locations Rockwell Financial Group has 2 office locations: Main Office: 240 W. OLD COUNTRY ROAD, SUITE 3 HICKSVILLE NY 11801 PHONE: 5164999453 OSJ: 2 William Street, #403, White Plains, NY 10601. Phone # (914) 328-7030. Fax: (914) 328-7036. Email: mhalkitis@therockwellfinancialgroup.com. Employees commute to this location Order taking and execution are done at both office locations. Alternative Physical Location of Employees In the event of a SBD, our staff will operate between the Main office and the White Plains, If it is necessary they will be moved to an alternate location. Customer Access to Funds and Securities Our firm does not maintain custody of customer funds or securities, which are maintained at our clearing firm Hilltopsecurities. Our contact with customers, regarding trading instructions, is done 100% via telephone. If telephone service is unavailable at one location, these instructions will be handled from a remote location or the Branch Manager can use his/her cell phone. If the main office is affected by a SBD, customers may call the White Plains office or Hilltop Securities , the clearing firm at 800 214-953- 4000. The Firm has made this information available to customers through its disclosure policy. If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of SEC Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation. Data Backup and Recovery RFG maintains its hard copy books and records at both the main office , the white plains office and Hilltop securities. The addresses and phone numbers are listed previously in this document. Michael Halkitis and Hugh Dunn are responsible for the maintenance of books and records at their respective locations. Most documents are transmitted to the clearing firm. RFG also maintains a back up copy of books and records in electronic format that is held at an alternative site. RFG generally backs up its  electronic records on a monthly basis. Hilltop Securities also backs up the firms customer records on a daily basis. In the event of a SBD that causes loss of our paper records, we will physically recover them from our other location. Should the SBD affect both offices, the firm would then retrieve records from the alternative site or Hilltop Securitiesy. Operational and Financial Assessments Operational Risk Operational Risk includes the firm’s ability to maintain communications with customers and to retrieve key activity records through its mission critical systems. RFG will use any means available to communicate with customers in the event of a SBD. This also applies to vendors, banks, critical business partners, regulators, etc. We will employ telephone (from either location), cell phones, e-mail, and fax. Again if one location is affected, RFG will rely on its alternate location. If both locations are affected, then alternates means such as cell phones will be employed Financial Risk Financial Risk involves the firm’s ability to fund operations and maintain adequate financing and sufficient capital. RFG compute its net capital on a daily basis. In the event of a SBD, RFG will evaluate its ability to maintain capital requirements and meet operational obligations. In the event RFG is unable to meet its obligations, RFG will explore other means of financing such as capital contributions from its parent company or other credit sources. If RFG cannot correct a capital deficiency, we will file notices with regulators and notify customer immediately of their options. Mission Critical Systems Our firm’s mission critical systems are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, 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. More specifically these systems include: Internet Access Trading, Clearance, and Portfolio Management Systems Accounting Systems Market Data and Research Telecommunications Facility Access Compliance Computer Hardware and Software Offsite Storage We have the primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking and order entry. Our clearing firm provides through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance and access to customer account and the delivery of funds and securities. Hilltop Securities will maintain a business continuity plan and the capacity to execute that plan. Both entities will notify us of any material change to their plan that might affect our business. Disclosure of Business Continuity Plan We provide in writing a BCP disclosure statement to customers at account opening. We also mail it to customers upon request. Updates and Review Our firm will update this plan whenever we have a material change to our operations, structure, business locations or to those of our clearing firm. In addition we will review this BCP annually to modify it for changes in our operations, structure, business locations or to those of our clearing firm. Senior Manager Approval Senior Management (Michael Halkitis and Hugh Dunn) have approved the Rockwell Financial Group Business Continuity Plan.