I. Emergency Contact Persons

Our firm’s two emergency contact persons are:

Edwin Garcia 914-625-4452 (cell), egarcia@bcpsecurities.com
Randall E. Pike, 203 550 1263 (cell), rpike@bcpsecurities.com

These names will be updated in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each year.

Rule: FINRA Rule 4370(f);

II. Firm Policy

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, our clearing agents, Pershing will assure customers prompt access to their funds and securities.

A. Significant Business Disruptions (SBDs)

Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

B. Approval and Execution Authority

Eric Spichiger, a registered principal, is responsible for approving the plan and for
conducting the required annual review. Edwin Garcia has the authority to execute this
for BCP.

C. Plan Location and Access

Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on R\:Compliance\Spichiger\BusinessContinuityPlan\BCP Business Continuity Plan Dec 2018.pdf and contained in periodic backups of our files. The tapes that hold the backups are stored at our vendor, Greenwich Computer Solutions.

III. Business Description

Our firm conducts business primarily in emerging market fixed income securities. Our firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders. All transactions are sent to our clearing firms, which executes our orders, compares them, allocates them, clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services mostly institutional customers. Our clearing firm is Pershing. Contact information is as follows: Pershing One Pershing Plaza, Jersey City, NJ 07399 Our contact person is Chris Fulco. He may be reached at 203-413-4350 or cfulco@pershing.com

IV. Office Locations

Our Firm has a main office, two Offices of Supervisory Jurisdictions (OSJ’s) and three sales offices.

Main Office

BCP Securities
289 Greenwich Ave., 4th Fl.
Greenwich, CT 06830

Its main telephone number is (203) 629 2181. This is the firm’s headquarters and is the
largest branch. Our employees travel to the office primarily by car or train. All facets of
the firm’s business including trading and order taking are taking place at this location.

OSJ’s

Baer Crosby and Pike, Agencia de Valores S.A.
Paseo de la Castellana, 91, 10th Floor, Suite 2,
28046 Madrid, Spain

Its main telephone number is 011 34 91 310 6980. Our employees travel to that office by
means of car and train. We engage in business origination, order taking and trading at
this location.

BCP Securities
1221 Brickell Avenue, suite 1170,
Miami, FL 33131

Its main telephone number is 305-358-6445. Our employees travel to that office by
means of car. We engage in order taking and trading at this location.

Branch Offices

BCP Securities Do Brasil Representacoes LTDA
Rua Visconde Piraja, 351 – Sala 1212,
Rio de Janeiro, RJ CEP 22410-000 Brazil

Its main telephone number is 011 55 21-2227-4160. Our employees travel to that office
by means of car and train. We engage in order taking at this location.

BCP Securities Asia Pte. LTD
24 Raffles Place,
#12-05A, Clifford Centre
Singapore, 048621

Its main telephone number is 011-65-6255-3171. Our employees travel to that office by
means of car and train. We engage in order taking at this location.

Bear Crosby Pike de Mexico
Paseo de los Tamarindos no. 90 / Torres Arcos Bosques
Torre 1 piso 11 oficina 11B
Bosques de las Lomas
Cuajimalpa de Morelos 05120
Mexico, CDMX

Its main telephone number is +52‐55‐50255500. Our employees travel to that office
primarily by means of car. We engage in order taking at this location.

BCP Securities
22917 Pacific Coast Highway
Suite 205
Malibu, CA 90265

Its main telephone number is 424‐210‐8466. Our employees travel to that office primarily
by means of car. We engage in order taking at this location.

V. Alternative Physical Location(s) of Employees

In the event of an SBD, many of our employees have access remotely via Bloomberg,
VPN, Pershing, FINRA, ACT, TRACE, OATS web-sites and email. For employees who
cannot access required systems should report to our systems vendor Greenwich Computer
Solutions 34 5th Street Stamford, CT 06878, 203-542-0754.

Rule: FINRA Rule 4370 (c)(6)

VI. Customers’ Access to Funds and Securities

Our firm does not maintain custody of customers’ funds or securities, which are
maintained at our clearing firm Pershing. In the event of an internal or external SBD, if
telephone service is available, our registered persons will take customer orders or
instructions and contact our clearing firm on their behalf, and if our Web access is
available, our firm will post on our Web site that customers may access their funds and
securities by contacting our clearing firm mentioned in Section III of our Business
Continuity Plan. The firm will make this information available to customers through
their 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 Securities Exchange Act Rule 15c3-l, 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.

Rules: FINRA Rule 4370(a); SEC Rule 15c-3-1;

VII. Data Back-Up and Recovery (Hard Copy and Electronic)

Our firm maintains its Primary hard copy books and records and its electronic records at 289 Greenwich Ave. 4th Fl., Greenwich, CT. Edwin Garcia is responsible for the maintenance of these books and records.

The firm’s trade tickets, order tickets, cancel/amend data and trade histories are available in Bloomberg. The firms clearing information including trade blotters and settlement information are maintained off site and available from our clearing firm, Pershing. Pershing as our clearing agents maintain electronically all data entered into their systems, including trades, cancels and corrects, confirms and account statements. Both Bloomberg and Pershing are 17a-3 and 17a-4 compliant.

The firm’s file server backs up its electronic records Monday through Friday to a separate hard drive located at 289 Greenwich Ave., 4th Fl. Greenwich, CT 06830 and to an NAS drive located at 1221 Brickell Ave., Suite 1170 Miami FL. 33131. Monthly backup, taken on the last Friday of each month are archived for 5 years. A copy of Friday’s full backup is also stored remotely with our vendor, Greenwich Computer Solutions in a fire and water resistant safe.

For the loss of electronic records, we 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.

Rule: NASD Rule 35JO(c)(l).

VIII. Financial and Operational Assessments

A. Operational Risk

In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter-parties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include Bloomberg, telephone and email. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic). Rules: FINRA Rule 4370(c)(l).

B. Financial and Credit Risk

In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our clearing firms, critical banks, and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including liquidating all positions where possible and seeking temporary forms of funding.

Rules: FINRA Rules 4370(c), (c)(8) & (g) (2).

IX. 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: NetExchangePro (Pershing), Bloomberg, QuickBooks, Trade Master Systems and internet access.

We have 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 entry. Our clearing firm 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.

Our clearing firm contract provides that our clearing firm will maintain a business continuity plan and the capacity to execute that plan. Our clearing firm represents that they will advise us of any material changes to their plan that might affect our ability to maintain our business. In the event of our clearing firm executes their plan, they represent that they will notify us of such execution and provide us equal access to the same services as its other customers. If we reasonably determine that our clearing firm has not or cannot put their plan in place quickly enough to meet our needs, or is otherwise unable to provide access to such services, our clearing firm represents that they will assist us in seeking services from an alternative source.

Our clearing firm represents that they back up our records at a remote site. Our clearing firm represents that they operate a back-up operating facility in a geographically separate area with the capability to conduct the same volume of business as its primary site. Our clearing firm has also confirmed the effectiveness of its back-up arrangements to recover from a wide scale disruption by testing.

Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption and status of critical infrastructure-particularly telecommunications-can affect actual recovery times. Recovery refers to 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.

A. Our Firm’s Mission Critical Systems

Order Taking

Currently, our firm receives orders from customers via the salesperson via telephone and Bloomberg. During an SBD, either internal or external, we will continue to take orders through any of these methods that are available and reliable, and in addition, as communications permit, we will inform our customers when communications become available to tell them what alternatives they have to send their orders to us. Customers will be informed of alternatives by telephone, email or Bloomberg.

Order Entry

Currently, our firm enters orders by recording them electronically and sending them to a variety of execution venues electronically.

In the event of an internal SBD, we will enter and send records to our clearing firm by telephone or fax. In the event of an external SBD, we will maintain the order in electronic or paper format, and deliver the order by the fastest means available when it resumes operations.

B. Mission Critical Systems Provided by Our Clearing Firms

Our firm relies, by contract, on our clearing firm to provide order execution, order comparison, order allocation, maintenance of customer accounts, delivery of funds & securities and access to customer accounts.

Rules: FINRA Rules 3510(c)(2)&(g)(l).

X. Alternate Communications between the Firm and Customers, Employees, and Regulators

A. Customers

We now communicate with our customers using the telephone, e-mail, Bloomberg, fax, U.S. mail, and in person visits at our firm or at their location. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a counter party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.

Rule: FINRA Rule 4370(c)(4).

B. Employees

We now communicate with our employees using the telephone, e-mail, Bloomberg, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. The size of the firm is small and each person is distributed an employee contact list with name, address, telephone number, cell number and email address. Rule: FINRA Rule 4370(c)(5). C. Regulators We are currently members of the following SROs: FINRA Boston. We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

Rule: FINRA Rule 4370(c)(9).

C. Regulators

We are currently members of the following SROs: FINRA Boston. We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

Rule: FINRA Rule 4370(c)(9).

XI. Critical Business Constituents, Banks and Counter-Parties

A. Business constituents

We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm.

Rules: FINRA Rule 4370(c)(7).

B. Banks

We have contacted our banks and lenders to determine if they can continue to provide the liquidity that we will need in light of the internal or external SBD. The bank maintaining our operating account is: Bank of America, 240 Greenwich Ave., Greenwich, CT, 203 629-4018. The institutions maintaining our Proprietary Account of Introducing Brokers/Dealers (PAIB account) is Pershing. If our banks and other lenders are unable to provide the liquidity, we will seek alternative financing immediately from other sources.

Rules: FINRA Rule 4370(c)(7).

C. Counter-Parties

Where the transactions cannot be completed, we will work with our clearing firm or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible.

Rules: FINRA Rule 4370(c)(7).

XII. Regulatory Reporting

Our firm is subject to regulation by: FINRA, SIPC and the State of Connecticut. We now file reports with our regulators electronically using e-mail. In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

Rule: FINRA Rule 4370(c)(8).

XIII. Disclosure of Business Continuity Plan

We will disclose our BCP to customers at the time the account is opened. Our BCP addresses the possibility of a future SBD and how we plan to respond to events of varying scope. In addressing the events of varying scope, our summary (1) states whether we plan to continue business during that scenario and, if so, our planned recovery time; and (2) provides general information on our intended response. Our Business Continuity Plan discloses the existence of back-up facilities and arrangements and is available for viewing on our website.

Rule: FINRA Rule 4370(e).

XIV. Updates and Annual Review

Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our firm will review this BCP annually, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm. It will be added to our annual review of procedures.

Rule: FINRA Rule 4370(b).

XV. Senior Manager Approval

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.

Rule: FINRA Rule 4370(d).

Signed:  

Title: Chief Compliance Officer